Talen Energy v. WCAB (James), Talen Energy v. WCAB (James)

Claimant, a handyman at Employer’s nuclear power plant, was struck from behind while stopped at a stop sign on the plant’s access road shortly after her shift on October 4, 2011.
The access road is controlled by Employer (posted as private, guarded gate area, Employer maintains road).
Claimant reported the accident to her supervisor, sought medical care the next day, and ultimately was restricted to light duty; she stopped working in June 2012 and filed a workers’ compensation Claim Petition for a low back injury with radiculopathy.
Employer conceded the injury occurred on Employer premises and that Claimant’s presence was required by her employment, but denied the injury arose in the course of employment and disputed that it was caused by a condition of the premises.
The Workers’ Compensation Judge (WCJ) granted the Claim Petition; the Workers’ Compensation Appeal Board (Board) affirmed in part; Employer appealed to this Court arguing the Slaugenhaupt three‑part test should apply and Claimant failed the causation prong.
The Court considered whether the injury was "in the course of employment" under Section 301(c)(1) and whether the Slaugenhaupt test was required or inapplicable because Claimant was furthering Employer’s interests while leaving work on Employer premises.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Claimant’s injury occurred in the course of employment under 77 P.S. § 411(1)	Claimant: injury occurred on Employer premises shortly after shift while exiting, so she was furthering Employer’s interests and injury is compensable.	Employer: Claimant was leaving work (not furthering Employer’s interests) and thus must satisfy Slaugenhaupt; she cannot show her injury was caused by a condition of the premises.	Held: Injury occurred on Employer premises within reasonable proximate time after shift; getting to/leaving workstation furthers employer’s interests, so Slaugenhaupt not required and claim compensable.

Epler v. North American Rockwell Corp., 393 A.2d 1163 (Pa. 1978) (employee injured between plant and parking lot shortly after shift is compensable if reasonably proximate to work hours)
Allegheny Ludlum Corp. v. Workers’ Comp. Appeal Bd. (Hines), 913 A.2d 345 (Pa. Cmwlth. 2006) (employee struck en route on employer sidewalk was furthering employer’s interest)
Motion Control Indus. v. Workmen’s Comp. Appeal Bd. (Buck), 603 A.2d 675 (Pa. Cmwlth. 1992) (parking‑lot injury while leaving work falls within course of employment; Slaugenhaupt not mandatory in such cases)
Ace Wire Spring & Form Co. v. Workers’ Comp. Appeal Bd. (Walshesky), 93 A.3d 923 (Pa. Cmwlth. 2014) (phrase "actually engaged in the furtherance of the business" construed liberally; ingress/egress can further employer’s interests)
PPL v. Workers’ Comp. Appeal Bd. (Kloss), 92 A.3d 1276 (Pa. Cmwlth. 2014) (Slaugenhaupt applies where location is not employer premises; distinguishes parking‑lot/premises ingress/egress cases)