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FLORIDA RECORD

Friday, March 29, 2024

First District Court rules woman's bowling injury during employer event is compensable

State Court
Bowling 596766 1280

TALLAHASSEE – The First District Court of Appeal has ruled that a woman's injury that she sustained while attending a work-related event was compensable.

The court reversed a decision made by a judge of compensation claims (JCC) in Karen Reynolds' appeal against Anixter Power Solutions and Travelers Insurance Co. 

"We determine that the injury sustained while bowling was work related pursuant to section 440.921, Florida Statutes, and reverse," Judge James R. Wolf wrote.

Reynolds appealed an order denying her claim for workers' compensation benefits for an ankle injury that she sustained while bowling with co-workers during work hours. The JCC deemed that the injury was the result of a recreational activity and that her injury was not compensable. 

Wolf noted the purpose of the bowling event was to “improve morale” and to discuss upcoming goals for the new year. The judge wrote that Reynolds was invited to the event as an employee and was therefore obligated to attend. Furthermore, the event was conducted within business hours.

Wolf also noted Reynolds was invited to the event via email and that "an electronic option to decline is insufficient to establish that participation in the event was voluntary." A footnote in the ruling states that the actual email invite was not introduced as evidence. 

Judge Lori S. Rowe dissented in the opinion.

"The JCC correctly determined that the bowling event Karen Reynolds attended with her co-workers was a 'recreational activity,'" Rowe wrote. "I would affirm the order denying compensability for the injury Reynolds sustained while bowling."

Rowe noted that Reynolds' supervisor testified the event was not mandatory and Reynolds admitted she accepted the invitation.

"Reynolds failed to present competent, substantial evidence to show that the bowling event was required as an incident of her employment or that it provided a substantial direct benefit to APS beyond improving employee health and morale," Rowe wrote.

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