BRIAN GRAWEHR VS. TOWNSHIP OF EAST HANOVER(DIVISION OF WORKERS' COMPENSATION), A-1686-15T3

Petitioner Brian Grawehr, a police officer, slipped on ice in the municipal parking lot at police headquarters on a day he was off, injuring his shoulder and later requiring surgery.
Grawehr went to headquarters that day to pick up a pay stub and check his personnel file for subpoenas because recent municipal court mergers had caused scheduling confusion and discipline issues for officers missing appearances.
There was no formal requirement that officers come in on off-days to check files, but testimony established it was not uncommon for "diligent" officers to do so and that the department experienced ongoing scheduling problems after the court merger.
The Township denied the injury arose out of employment; the judge of compensation held a trial limited to compensability and found Grawehr’s presence served a benefit to the employer and the injury was compensable.
The judge awarded partial disability benefits (27.5% disability) and medical expenses; the Appellate Division affirmed, concluding Grawehr’s activity at the premises was at least incident to his employment.

Issue	Plaintiff's Argument (Grawehr)	Defendant's Argument (Township)	Held
Whether an injury on employer premises on an off-day is compensable	Grawehr was at headquarters to check for subpoenas (protect employer interest) and pick up a stub; his presence aided the employer	Grawehr was off-duty and at headquarters for personal reasons; no employer benefit and not in course of employment	Held compensable: his actions were mutually beneficial and incidental to employment
Whether situs alone suffices for coverage	Situs plus causal connection; his presence created a work-related risk	Situs without causal connection is insufficient	Held situs contributes but a causal link is required; here causal connection satisfied
Applicability of "premises rule"/N.J.S.A. 34:15-36 to off-duty injuries	Premises rule covers arrival/departure when on employer premises fulfilling job-related duties	Off-duty status negates commencement/termination of employment	Held premises rule applies when employee is reasonably fulfilling duties or doing something incidental thereto, even off-duty
Whether judge's TCA comments prejudiced the Township	Not addressed as harmful	Judge's TCA remarks showed bias	Held no prejudice to Township from TCA discussion

Lindquist v. City of Jersey City Fire Dep't, 175 N.J. 244 (2003) (appellate deference to factfindings in workers' compensation)
Coleman v. Cycle Transformer Corp., 105 N.J. 285 (1986) (causation standard: injury more probable to be employment-related than not)
Kristiansen v. Morgan, 153 N.J. 298 (1998) (premises rule and scope of employment situs analysis)
Crotty v. Driver Harris Co., 49 N.J. Super. 60 (App. Div.) (1958) (elements of "in the course of employment")
Konitch v. Hartung, 81 N.J. Super. 376 (App. Div.) (1963) (parking-lot injuries compensable if in course of employment)
Salierno v. Micro Stamping Co., 136 N.J. Super. 172 (App. Div.) (1975) (injury during employer-beneficial activity on premises compensable)