Workers' comp benefits awarded to woman injured bowling with co-workers
Karen Reynolds attended a bowling event with co-workers from Anixter Power Solutions during her paid work shift and injured her ankle.
A Florida court, reversing a ruling by a workers’ compensation judge, has awarded workers’ compensation benefits to a woman for an injury she sustained while bowling with co-workers during regular working hours.
The case
After Karen Reynolds attended a bowling event with co-workers from Anixter Power Solutions during her paid work shift and injured her ankle, she sought workers’ compensation benefits.
A workers’ compensation judge concluded that the bowling event was a “recreational activity” and that Ms. Reynolds was not entitled to compensation.
She asked a court to review that ruling and find her injury compensable under Florida Statutes Section 440.092(1).
Florida law
Florida Statutes Section 440.092(1) provides:
Recreational or social activities are not compensable unless such recreational or social activities are an expressly required incident of employment and produce a substantial direct benefit to the employer beyond improvement in employee health and morale that is common to all kinds of recreation and social life.
The court’s decision
The court reversed, finding that the injury Ms. Reynolds sustained while bowling was compensable under Section 440.092(1) because the activity was an expressly required incident of employment and produced a substantial direct benefit to her employer, Anixter, beyond improvement in employee health and morale.
In its decision, the court explained that the bowling event was during regular work hours, that Anixter paid employees who attended the event, and that Ms. Reynolds “was not told” that she could have remained at work or taken a vacation day rather than attend the event. According to the court, “[n]o other alternative was offered by the employer.”
Moreover, the court added, the purpose of the event was to improve morale and, as testified to by Ms. Reynolds’ supervisor, to discuss “some of our goals for the next year.”
The court reasoned that if an employer invited an employee during work hours to discuss goals for the employee’s department, the employee would be “obligated to attend.” Here, the court continued, the employer’s invitation was sent by email and could be accepted or declined, but an electronic option to decline was “insufficient to establish that participation in this event was voluntary.”
Reiterating that the bowling was conducted during regular work hours and that one purpose of the event was to discuss goals for the upcoming year, the court concluded that, “[n]o reasonable person in [Ms. Reynolds’] position would have believed that the activity was not a required incident of employment.”
The case is Reynolds v. Anixter Power Solutions and Travelers Ins. Co., No. 1D19-0231 (Fla. Ct. App. Dec. 10, 2019).
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