Allenbaugh v. Illinois Workers' Compensation Comm'n, 58 N.E.3d 872

Claimant Jason Allenbaugh, a Peoria police patrol officer who normally worked second shift, was ordered to attend mandatory training beginning at 8:00 a.m. on March 5, 2013.
While driving in hazardous, snowy/icy conditions en route to police headquarters, an oncoming car crossed the center line and struck claimant; he sustained neck and back injuries.
Claimant left home carrying required police gear for training (nightstick, gun belt, handcuffs, Taser, uniform) and was not responding to any call or emergency when the crash occurred.
The arbitrator found the injury arose out of and in the course of employment; the Illinois Workers’ Compensation Commission reversed, concluding claimant was commuting in his personal vehicle and not under employer control.
The Commission rejected application of the traveling-employee doctrine and distinguished City of Springfield because claimant was not equipped with devices (e.g., radio/beeper) that allowed employer control while off duty.
The circuit court confirmed the Commission’s decision; claimant appealed and the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether respondent retained sufficient control over claimant while commuting so injury was within scope of employment	Allenbaugh: He was ordered to attend mandatory training outside normal hours and could be disciplined; employer thus controlled him	Respondent: No continuous control; claimant was off duty, not on-call, and not carrying devices that enabled employer control	Held: No. Employer control insufficient; City of Springfield is distinguishable and does not support coverage
Whether claimant was a "traveling employee" making the commute compensable	Allenbaugh: Regular job requires extensive driving; attending training was work travel outside normal shift, so exception applies	Respondent: At time of crash claimant was commuting in personal vehicle to workplace, not performing work duties; traveling-employee doctrine doesn't cover ordinary commutes	Held: No. Traveling-employee doctrine does not extend to a normal commute to workplace in these facts

City of Springfield v. Industrial Comm’n, 244 Ill. App. 3d 408 (Ill. App. Ct. 1993) (employer control via 24-hour car, radio/beeper supports coverage during off-duty travel)
Venture/Newberg-Perini v. Illinois Workers’ Compensation Comm’n, 2013 IL 115728 (Ill. 2013) (defines traveling employee and scope of compensable travel)
Kemp v. Industrial Comm’n, 264 Ill. App. 3d 1108 (Ill. App. Ct. 1994) (standard for reviewing whether injury arose out of and in course of employment)