Vaughan's Landscaping & Maintenance v. Dodson

Summary

The Supreme Court of Virginia held that a worker’s injuries sustained while being transported home by his employer arose out of and in the course of employment. The court rejected arguments that the worker’s intoxication and an intervening stop to drink and play horseshoes severed the employment connection, emphasizing that the employer resumed transporting the worker pursuant to the employment-related transportation arrangement.

Holdings

1. An injury sustained while an employer transports an employee to the employee's requested destination is compensable when the transportation is part of the employer's agreement to provide transportation to and from work.
2. The principle that an employee's advanced intoxication may constitute abandonment of employment did not apply because Vaughan did not expect Dodson to perform additional work after the day's work was completed. The drinking and horseshoes stop did not defeat compensability because the case concerned the employer's resumption of transportation to Luray, not an employee's deviation during the transportation itself.

Questions Presented

1. Whether Dodson's injury arose out of and in the course of his employment when his employer transported him after work following a period of drinking and pitching horseshoes.
2. Whether Dodson's severe intoxication constituted such an abandonment of employment or deviation from the employment-related purpose of the trip that the injury was not compensable.

Disposition

affirmed