Mandeep Rana v. WCAB (Asha Corporation); 1401 C.D. 2016; filed Sep. 29, 2017; Judge Cosgrove

Fatal motor vehicle accident occurred within the course and scope of employment because the decedent was responding to an operational issue at one of his employer’s locations.

According to the Commonwealth Court’s analysis, the decedent, as manager for one of the employer’s many locations, was a stationary employee as to that store. However, the court found that the decedent was not a stationary employee with regard to the other locations but, rather, a traveling employee. Consequently, the court concluded that the decedent’s motor vehicle accident was within the scope and course of his employment. The court also said that the accident could also be deemed compensable under the special assignment doctrine. The court noted that the decedent, having already worked his regular shift, was travelling to the other store to investigate a situation on behalf of the employer. 

 

Case Law Alerts, 1st Quarter, January 2018

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