John C. Morris v. Custom Kitchen & Baths, 64 N.E.3d 912

John C. Morris, sole proprietor of Custom Kitchen & Baths (CKB) and a licensed general contractor, routinely performed unpaid community construction projects (mostly Boy Scout projects), donating materials, tools, vehicle use, and his contractor’s license.
In August 2012 Morris supervised and materially contributed to construction of a 10' x 10' storage shed for Olivet Presbyterian Church as an Eagle Scout/Boy Scout volunteer project; the project required a licensed contractor and Morris deducted donated materials as a business expense.
While working on the shed Morris fell from the roof and sustained a serious leg fracture requiring multiple surgeries.
Morris’ workers’ compensation carrier and two liability carriers paid medical bills and some benefits; Morris filed an Application for Adjustment of Claim with the Indiana Worker’s Compensation Board, which denied his claim.
The full Board affirmed, finding the project primarily advanced Morris’ son’s Eagle Scout goals and was not work "arising out of and in the course of" Morris’ employment. Morris appealed; CKB cross‑appealed seeking reimbursement of payments made on Morris’ behalf.
The Court of Appeals reversed, holding the injury arose out of and in the course of Morris’ employment and remanded for determination of benefits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Morris’s injury "arose out of and in the course of" employment under Indiana Code § 22‑3‑2‑2(A)	Morris: his volunteer projects were connected to his business interests (goodwill, networking, direct business), used his license, tools, vehicle, and could not have been completed without him — thus the injury is employment related.	CKB: the Olivet Project was a personal/Scout activity benefiting his son; employer "sponsorship" was lacking and Morris was unpaid, so injury was not within scope of employment.	Court: Held injury did arise out of and in the course of employment — Morris’s contributions, license requirement, business benefit, and nexus to his contracting business make the activity incidental to employment.

Knoy v. Cary, 813 N.E.2d 1170 (Ind. 2004) (after‑hours or community activities can be compensable when employer’s/business interests connect the activity to employment)
Noble v. Zimmerman, 146 N.E.2d 828 (Ind. 1957) (employer‑sponsored after‑hours recreation can be compensable where tied to business interests)
Ski World, Inc. v. Fife, 489 N.E.2d 72 (Ind. Ct. App. 1986) (employer encouragement/sponsorship of after‑hours party created nexus to employment)
Milledge v. Oaks, 784 N.E.2d 926 (Ind. 2003) (explains "arising out of" and "in the course of" employment standards)
Daugherty v. Industrial Contracting & Erecting, 802 N.E.2d 912 (Ind. 2004) (Worker’s Compensation Act to be liberally construed)