The Supreme Court of Georgia has ruled in favor of a State Farm employee who was injured when she slipped and fell on a wet floor in the break room in the middle of the day while getting ready to eat her lunch was injured during the course of employment, because it logically follows that her injury was causally connected to the conditions under which she worked, and therefore, her injury arose from her employment. The case is Frett v. State Farm Emple. Workers' Comp., 2020 Ga. LEXIS 458.

According to the undisputed case facts, on the day of the incident, State Farm employee Rochelle Frett logged out of the phone system for her scheduled, unpaid forty-five-minute lunch break and went to the breakroom to microwave her food. While exiting the breakroom to enjoy her lunch outside the building, she slipped on some water on the floor and fell.

Frett was initially awarded workers' compensation benefits by an administrative law judge. On appeal, the State Board of Workers' Compensation on appeal denied her claim for workers' compensation and a superior court later upheld the decision. The Court of Appeals affirmed the decision holding that Frett suffered no injury compensable under the Act because Frett sustained her injury during a scheduled break so the injury did not arise out of her employment.