Sign In
Events
Newsletters
Search

Close

Close Search

Cancel

SEARCH
MY LAW.COMNEW

Mayor and Aldermen of the City of Savannah v. Stevens

An officer who was injured in an accident on her way to work in her own personal vehicle was not entitled to workers' compensation benefits.

X

Thank you for sharing!

Your article was successfully shared with the contacts you provided.

We granted certiorari to determine whether the Court of Appeals correctly held that the injuries suffered by police office Eunita Stevens in a car accident while on her way to work arose out of and in the course of her employment.1 Because Stevens’ injuries were in no way related to her duties as a police officer, they did not arise out of her employment. Therefore, we reverse. Prior to the accident on November 30, 1999, Stevens worked as an administrative corporal in the Savannah Police Department. The accident occurred as Stevens was driving to work in her personal car and wearing her police uniform. The Administrative Law Judge found that the accident arose out of and in the course of Stevens’ employment because, according to the policies of the Savannah Police Department, “she was subject to be called to duty 24 hours per day and was expected to preserve the peace and enforce the law even when off duty.” The ALJ Appellate Division, Superior Court, and Court of Appeals all affirmed, finding the decision to be supported by some evidence. That decision, however, unjustifiably extends the scope of a public employer’s liability for employee injuries under established workers’ compensation law. It would require workers’ compensation liability to issue any time an off-duty, uniformed police officer were injured within the city or county limits where they are charged with enforcing the law, no matter whether the injury in any way arose out of the officer’s employment.

1. Generally, an injury is compensable only if it arises out of and in the course of the employment.2 The test presents two independent and distinct criteria, and an injury is not compensable unless it satisfies both.3

Trending Stories

 
Reprints & Licensing
Mentioned in a Law.com story?

License our industry-leading legal content to extend your thought leadership and build your brand.

LEARN MORE

More From ALM

Premium Subscription
With this subscription you will receive unlimited access to high quality, online, on-demand premium content from well-respected faculty in the legal industry. This is perfect for attorneys licensed in multiple jurisdictions or for attorneys that have fulfilled their CLE requirement but need to access resourceful information for their practice areas.
View Now
Team Accounts
Our Team Account subscription service is for legal teams of four or more attorneys. Each attorney is granted unlimited access to high quality, on-demand premium content from well-respected faculty in the legal industry along with administrative access to easily manage CLE for the entire team.
View Now
Bundle Subscriptions
Gain access to some of the most knowledgeable and experienced attorneys with our 2 bundle options! Our Compliance bundles are curated by CLE Counselors and include current legal topics and challenges within the industry. Our second option allows you to build your bundle and strategically select the content that pertains to your needs. Both options are priced the same.
View Now
Go to CLE Center
GlobeSt. Women of Influence (WOI) 2024
July 22, 2024 - July 24, 2024
Lake Tahoe, CA

GlobeSt. Women of Influence Conference celebrates the women who drive the commercial real estate industry forward.


Learn More
New York Legal Awards 2024
September 05, 2024
New York, NY

The New York Law Journal honors attorneys and judges who have made a remarkable difference in the legal profession in New York.


Learn More
African Legal Awards 2024
September 06, 2024
Johannesburg

The African Legal Awards recognise exceptional achievement within Africa s legal community during a period of rapid change.


Learn More
Go to Events Go to Webcasts
Director of Legal Affairs

WittKieffer is proud to partner with Mom's Meals in the search for their Director of Legal Affairs. Mom's Meals is an investor-owned compan...


Apply Now ›
Trial Attorney Personal Injury.

Nutley Law firm concentrating in plaintiff's personal injury for plaintiff seeks an Attorney with three or more years of experience in New J...


Apply Now ›
MID-SENIOR LEVEL EMPLOYMENT ASSOCIATE OR PARTNER WANTED FOR BOUTIQUE FIRM OPPORTUNITY TO INHERIT AND GROW PRACTICE (Atlanta, GA)

Our client, an outstanding boutique litigation firm based in Atlanta, is seeking to add an experienced Employment Litigation Attorney to the...


Apply Now ›
Go to Lawjobs
Lawyers of Distinction
06/27/2024
The American Lawyer

Professional Announcement


View Announcement ›
SMGQ Law
06/21/2024
Daily Business Review

Full Page Announcement


View Announcement ›
Blume Forte Fried Zerres & Molinari
06/14/2024
New Jersey Law Journal

Professional Announcement


View Announcement ›
Go to Professional Announcements