Williams v. Petromark Drilling, LLC, 303 P.3d 719

Williams, 23, worked as a back-up hand for Petromark drilling; travel between drill sites was intrinsic to the job and travel arrangements were industry-standard; he rode with Roach or in personal vehicles and was not paid for travel; Roach received mileage for transporting crew; Williams’ pay started at the drill site and ended when he clocked out; October 10, 2010, Williams rode with LaMaster back to Pawnee Rock, unbelted, vehicle rollover occurred after a tire issue; Williams was not wearing a seatbelt and did not know Petromark’s seatbelt policy; ALJ denied compensation, Board reversed and awarded compensation, Petromark appeals; issue centers on going-and-coming rule and inherent-travel exception

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the accident arose out of and in the course of employment under the going-and-coming rule	Petromark: going-and-coming rule bars the claim; Williams’ travel to the homeward route was not in furtherance of employment	Board: inherent-travel exception applies because travel is an intrinsic part of the drilling job, so within employment	Reversed; going-and-coming rule controls and inherent-travel exception does not apply

Messenger v. Sage Drilling Co., 9 Kan. App. 2d 435 (1984) (inherent travel recognized where travel furthers employer's interests)
Craig v. Val Energy, Inc., 47 Kan. App. 2d 164 (2012) (inherent-travel exception applicable where travel serves employer’s interests)
LaRue v. Sierra Petroleum Co., 183 Kan. 153 (1958) (travel is inherently, not personally motivated; exception may apply but depends on employer interests)
Hughes v. Ad Astra Information Systems, 294 Kan. 413 (2012) (travel as part of driller’s duties; going-and-coming analysis relevant to inherent-travel consideration)
Rinke v. Bank of America, 282 Kan. 746 (2005) (standard for determining whether injury arose out of employment; going-and-coming framework)