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Mayor and Aldermen of the City of Savannah v. Stevens

An officer who was injured in an accident on her way to work in her own personal vehicle was not entitled to workers' compensation benefits.

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We granted certiorari to determine whether the Court of Appeals correctly held that the injuries suffered by police office Eunita Stevens in a car accident while on her way to work arose out of and in the course of her employment.1 Because Stevens’ injuries were in no way related to her duties as a police officer, they did not arise out of her employment. Therefore, we reverse. Prior to the accident on November 30, 1999, Stevens worked as an administrative corporal in the Savannah Police Department. The accident occurred as Stevens was driving to work in her personal car and wearing her police uniform. The Administrative Law Judge found that the accident arose out of and in the course of Stevens’ employment because, according to the policies of the Savannah Police Department, “she was subject to be called to duty 24 hours per day and was expected to preserve the peace and enforce the law even when off duty.” The ALJ Appellate Division, Superior Court, and Court of Appeals all affirmed, finding the decision to be supported by some evidence. That decision, however, unjustifiably extends the scope of a public employer’s liability for employee injuries under established workers’ compensation law. It would require workers’ compensation liability to issue any time an off-duty, uniformed police officer were injured within the city or county limits where they are charged with enforcing the law, no matter whether the injury in any way arose out of the officer’s employment.

1. Generally, an injury is compensable only if it arises out of and in the course of the employment.2 The test presents two independent and distinct criteria, and an injury is not compensable unless it satisfies both.3

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