Allied Fire Protection Systems and Zurich American Ins. Co. v. WCAB (Warner), Allied Fire Protection Systems and Zurich American Ins. Co. v. WCAB (Warner)

Decedent was a long‑time vice president/project manager for Allied Fire Protection who spent ~80% of time at an office in Falconer, NY and ~20% traveling to job sites. He normally started and ended his day at the office but sometimes went directly to job sites depending on proximity.
On December 20, 2012, Decedent left home in a company vehicle to bid a job at Rouse Estates; he was involved in a fatal motor vehicle accident en route. He occasionally used a company vehicle when his personal truck was unavailable.
Decedent had pre‑existing hypertension and coronary artery disease; treating physician testified Decedent may have had a stroke before the crash but that the crash injuries were a significant contributing factor in his death.
Claimant (his widow) filed a fatal claim petition asserting the death arose in the course and scope of employment and sought benefits and funeral expense reimbursement; Employer denied material allegations.
The WCJ found Decedent was on a special mission and furthering Employer’s business by bidding the job and avoiding backtracking to the office; the Board affirmed on the alternative ground that Decedent was a traveling employee. Employer appealed to this Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Decedent was acting in the course and scope of employment when he died (i.e., exception to the going‑and‑coming rule applies)	Warner: Decedent was on a special mission / furthering employer’s business by going directly from home to bid the Rouse Estates job, avoiding backtracking and saving employer time/costs	Employer: Going‑and‑coming rule applies; Decedent was commuting and not on a work assignment (challenges to special mission and traveling‑employee exceptions)	Court affirmed: special circumstances exception (furthering employer’s business) satisfied; award affirmed

Reading Anthracite Co. v. Workers’ Comp. Appeal Bd. (Felegi), 789 A.2d 404 (Pa. Cmwlth. 2001) (claimant bears burden to prove death arose in course of employment)
Peer v. Workmen’s Comp. Appeal Bd. (B & W Constr.), 503 A.2d 1096 (Pa. Cmwlth. 1986) (going‑and‑coming rule generally bars commute injuries)
Wachs v. Workers’ Comp. Appeal Bd. (Am. Office Sys.), 884 A.2d 858 (Pa. 2005) (four exceptions to going‑and‑coming rule: transportation contract, no fixed place of work, special mission, special circumstances furthering employer)
William F. Rittner Co. v. Workmen’s Compensation Appeal Board (Rittner), 464 A.2d 675 (Pa. Cmwlth. 1983) (company vehicle and need to be available to respond to emergencies can create special circumstances)
Gen. Elec. Co. v. Workmen’s Comp. Appeal Bd. (Valsamaki), 593 A.2d 921 (Pa. Cmwlth. 1991) (WCJ may draw reasonable inferences from evidence)
MKP Enterprises, Inc. v. Underground Storage Tank Indemnification Bd., 39 A.3d 570 (Pa. Cmwlth. 2012) (appellate review views evidence in light most favorable to prevailing party)