Ralphs Grocery Co. v. Workers’ Compensation Appeals Board

Brief Fact Summary.

Moeller’s with filed for worker’s compensation benefits after her husband died from a heart attack following being laid off from Ralphs Grocery Co.

Synopsis of Rule of Law.

An employee is not entitled to worker’s compensation for an injury that does not arise out of the course of employment.

Facts.

Moeller was laid off after being on disability leave from Ralphs Grocery Co. (Ralphs). Ralphs called Moeller the next day, informing Moeller that he could return to work the next day with lower pay, part-time, and without benefits. Moeller suffered a heart attack and died after the phone call. Moeller was suffering from colon cancer at the time of the phone call. Moeller’s doctors claimed that Moeller died after finding out that he could only work part-time without benefits. Moeller’s wife filed for  and was awarded worker’s compensation benefits after her husband died from a heart attack following being laid off from Ralphs Grocery Co.

Issue.

Whether an employee is entitled to worker’s compensation for an injury that does not arise out of the course of employment?

Held.

No. The decision of the Workers’ Compensation Board is annulled. Mueller suffered the heart attack outside of his employment with Ralphs  because he was laid-off at the time of the phone call, and even if he was still employed by Ralphs, Mueller would not be due to return to work until the next day.

Discussion.

An employee is not entitled to worker’s compensation for an injury that does not arise out of the course of employment. The injury suffered by the employee must be linked to the employment in some manner. The going and coming rule suspends an employee’s employment from the time he leaves work and the time he resumes his work.