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Workers' Compensation for Employee Injured at Home

In Ae Clevite, Inc. v. Labor Commission, the Utah Court of Appeals recently affirmed an award of workers' compensation benefits to an employee injured at his home. The plaintiff worked as a district sales manager for an automotive supply company. His employer authorized his use of his home as a "base of operations" and routinely delivered business correspondence and supplies to his home. On the day of his injury, the plaintiff was waiting for a package from his employer. He saw the postman approach, and decided to spread salt on his icy driveway as a safety precaution. While spreading the salt, plaintiff slipped and suffered a crippling neck injury. The Labor Commission determined that plaintiff's injury occurred at a place where he was authorized to render services to his employer and was incidental to his efforts to advance his employer's interests. Accordingly, the Commission found him eligible for workers' compensation benefits, and the Court of Appeals agreed.

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