Lutheran Senior Services Management Co. v. Workers' Compensation Appeal Board, 154 A.3d 892

Claimant (Director of Maintenance) was injured in a car crash driving from home to work on March 13, 2014, after being asked by his supervisor to come in to fix malfunctioning security cameras.
Claimant was sick and had intended to take the day as a sick day, but accepted the supervisor’s request to come in because other qualified employees were unavailable.
Employer had an "on call" system; non‑exempt employees were paid (or credited) from the time they left home when responding to a call and could record a 3‑hour minimum; Claimant, though salaried/exempt, testified he received comp time and was treated door‑to‑door when called in.
WCJ found Claimant credible, concluded special circumstances existed that made his trip a ‘‘special mission’’/furtherance of Employer’s business, and credited treating physician that Claimant was totally disabled from the accident.
The Board affirmed, framing the case under the "special circumstances" exception to the coming‑and‑going rule; Employer appealed to the Commonwealth Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Claimant’s travel from home to work is compensable under the coming‑and‑going rule exceptions (special circumstances/special mission)	Claimant: He was requested to come in for an emergency camera repair, was on‑call, would not have left home but for Employer’s request, and was on the clock (comp time) from leaving home.	Employer: Travel was ordinary commute; Claimant failed to prove an exception to the coming‑and‑going rule and was not acting in course and scope of employment.	Court affirmed Board/WCJ: special circumstances existed (employer request for convenience/business, not mere convenience to employee); compensable.

Williams v. Workers’ Compensation Appeal Board (Matco Electric Co., Inc.), 721 A.2d 1140 (Pa. Cmwlth. 1998) (explains four exceptions to the coming‑and‑going rule)
Simko v. Workers’ Compensation Appeal Board (United States Steel Corp.), 101 A.3d 1239 (Pa. Cmwlth. 2014) (scheduling/regular duties limit special circumstances exception)
LoPresti v. Workers’ Compensation Appeal Board (Gulf Construction Co.), 384 A.2d 1017 (Pa. Cmwlth. 1978) (employer request for an employee to act for employer’s convenience can create special circumstances)
City of Philadelphia v. Workers’ Compensation Appeal Board (Stewart), 728 A.2d 431 (Pa. Cmwlth. 1999) (being on‑call infrequently can render travel a special assignment)
William F. Rittner Co. v. Workers’ Compensation Appeal Board, 464 A.2d 675 (Pa. Cmwlth. 1983) (special circumstances where employer required vehicle availability to respond to emergencies)
Muir v. Wilson Cola Co., 168 A.2d 588 (Pa. Super. 1961) (payment from "door to door" supports application of special circumstances exception)