Stokes v. Coweta County Board of Education, 313 Ga. App. 505

Stokes, employed as head custodian at an elementary school, unlocked a gated driveway prior to opening it for others.
On May 3, 2010, at 5:45 a.m. in dark, rainy conditions, her car began rolling downhill as she unlocked the gate.
She ran toward the car to stop it, tripped, and was knocked down; the car rolled over her left foot.
She required amputation days later due to injuries sustained.
The ALJ awarded benefits; the Board reversed; the Superior Court affirmed; the Court of Appeals reverses and remands for action consistent with this opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the injury arises out of employment	Stokes's actions were a direct response to job duties at the gate.	Board found the pursuit was a personal mission not connected to duties.	Arising out of employment recognized; not a deviation.
Whether the injury occurred in the course of employment	Injury occurred while on duty at the gate, within work hours.	Board treated incident as outside the course due to personal pursuit.	In the course of employment; within work duties.
Whether the Board erred by applying the deviation rule	Stopping the rolling car was dictated by job duties and emergency; not a personal deviation.	Pursuit of personal property constituted deviation from employment.	Board erred; remand to consider correct legal principles.

Syntec Indus., Inc. v. Godfrey, 269 Ga. 170 (1998) (appellate division credibility and substitution of findings guidance)
Murph v. Maynard Fixturecraft, 252 Ga. App. 483 (2001) (remand when Board relies on erroneous legal theory)
Ray Bell Constr. Co. v. King, 281 Ga. 853 (2007) (broad humanitarian scope of Workers' Comp. Act; causal connection standard)
Miles v. Brown Transport Corp., 163 Ga. App. 563 (1982) (injury on employer's premises during work hours presumed arising out of and in course)