Leordeanu v. American Protection Insurance Co., 330 S.W.3d 239

Leordeanu, a pharmaceutical sales rep, began and ended a day with employer-related travel, including dinners and sales calls, before an injury on a route that included a stop at an employer storage unit.
She drove a company-provided car and was on a route that in part served the employer’s business and in part served personal travel plans.
APIC denied workers’ compensation benefits, asserting the injury occurred outside the course and scope of employment.
The Texas Workers’ Compensation Act defines course and scope with two components and contains travel exclusions and exceptions, including the “coming and going” rule and the “dual purpose” rule.
The court of appeals reversed a jury verdict for Leordeanu, holding no evidence supported that the injury occurred in the course and scope of employment, prompting review by the Texas Supreme Court.
The Court held that travel to and from the place of employment falls under subsection (A) of 401.011(12) and that the dual-purpose travel rules under subsection (B) apply only to travel other than coming and going, affirming the trial court and reversing the court of appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether homeward travel with dual business/personal purposes falls within course and scope.	Leordeanu’s dual business purpose and employer-directed elements bring the travel within course and scope.	Travel to home is excluded unless covered by subsection (A) or the dual-purpose requirements of (B) apply.	Yes; only subsection (A) applies to coming/going travel, and Leordeanu’s travel was work-related.
Whether the dual-purpose rule applies to coming-and-going travel.	Dual-purpose travel should be compensable if business purpose exists.	Dual-purpose travel is addressed under (B) for non-coming-and-going scenarios.	No for coming-and-going travel; (B) applies to other dual-purpose travel.
Whether there was evidence that the travel originated in the employer’s business and furthered the employer’s affairs.	The trip included employer business stops and duties, establishing furtherance.	Evidence does not show the trip originated in the employer’s business.	There was evidence supporting the jury’s finding that the injury occurred in the course and scope of employment.

Evans v. Ill. Employers Ins. of Wausau, 790 S.W.2d 302 (Tex. 1990) (general rule: injuries while traveling to/from work usually not compensable; exceptions exist)
Smith v. Texas Employers’ Insurance Ass’n, 105 S.W.2d 192 (Tex. 1937) (two-part test: injury must occur in the course of employment and originate in employer’s work)
Shelton v. Standard Ins. Co., 389 S.W.2d 290 (Tex. 1965) (early recognition of travel-related exceptions to the coming-and-going rule)
Marks’ Dependents v. Gray, 251 N.E.2d 181 (N.Y. 1929) (dual-purpose travel test: business necessity vs. personal purpose)
Janak v. Texas Employers’ Ins. Ass’n, 381 S.W.2d 176 (Tex. 1964) (legislature adopted dual-purpose rule; articulation of tests)