When a Teleworker Trips Over Her Dog While Working from Home, the Court Must Decide Compensability

A teleworker's fall over a family pet highlights how questions about compensability and causation can be trickier when injuries occur off site.
By: | August 19, 2019

On the day Tammitha Valcourt-Williams tripped over her dog and injured her hip, shoulder and knee, she was technically on the clock, working from home as a workers’ compensation claims adjuster for Sedgwick CMS.

The work-from-home arrangement had been set up with Sedgwick prior to the incident. Because she was working during the time of injury, Valcourt-Williams sought workers’ compensation benefits. However, Sedgwick denied the claim.

It said that her actions at the time of injury were not part of her duties as a claims adjuster.

That’s because Valcourt-Williams had been brewing a cup of cappuccino in her kitchen. When she reached for her coffee mug, one of her two dogs got in the way and tripped her. To Sedgwick, Valcourt-Williams’ injuries stemmed from personal affairs; not work.

A lower court judge ruled in favor of Valcourt-Williams, calling the injury compensable. He claimed that by having a work-from-home arrangement in place, Sedgwick had “imported the work environment into the claimant’s home and the claimant’s home into the work environment.”

Sedgwick appealed.

In court, Sedgwick agreed that Valcourt-Williams’ injuries had occurred during work hours.

It also said that she was entitled to coffee breaks much like someone would be while working in the office. But, it argued, her injury did not arise out of the duties of her employment.

Scorecard: The appeals court decided Tammitha Valcourt-Williams is not eligible for workers’ comp, due in part because her accident had no “occupational causation.”

Takeaway: As the workforce turns more and more to the gig economy, employers should review work-from-home terms to keep their employees informed and safe. &

Autumn Demberger is a freelance writer and can be reached at [email protected].

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