Woodard v. Cassens Transport Co.
2012 Ohio 4015
Ohio Ct. App.2012Background
- Cassens employed Woodard as an over‑the‑road car hauler; he traveled extensively and stayed in hotels using a Cassens/CLC lodging program.
- Cassens’ CBA required lodging during federally mandated rest periods and designated lodging; Cassens paid lodging and related costs but not meals or other incidental expenses.
- Woodard stayed at a hotel in Lafayette, Indiana after a late-day delay and used a CLC card to pay for the room while awaiting a backhaul load.
- Cassens instructed Woodard to stay overnight to pick up a backhaul load, extending the trip and keeping him away from his home terminal.
- Woodard slipped and fell in a hotel bathroom while off‑duty en route to the next load, sustaining an acute left knee sprain.
- Industrial Commission and trial court initially found Woodard entitled to workers’ compensation; Cassens challenged, leading to de novo review in the trial court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Woodard’s injury occurred in the course of and arising out of employment | Woodard (Woodard) was traveling for work and injured while performing employment duties while staying at an employer-approved hotel. | Woodard’s injury occurred during a personal, off‑duty bathroom visit with no sufficient nexus to employment. | Not compensable; injury not arising out of employment; traveling employee status does not automatically prevail. |
Key Cases Cited
- Fisher v. Mayfield, 49 Ohio St.3d 275 (1990) (two-prong test: in the course of and arising out of employment; liberal construction in employee’s favor)
- Lord v. Daugherty, 66 Ohio St.2d 441 (1981) (factors for causal connection: proximity, control, and employer benefit)
- Ruckman v. Cubby Drilling, Inc., 81 Ohio St.3d 117 (1998) (activity must be related to employment; nexus analysis)
- Elsass v. Commercial Carriers, Inc., 73 Ohio App.3d 112 (1992) (off-duty status not dispositive; proximity/time/place/purpose analysis)
- Jones v. USF Holland, Inc., 2011-Ohio-2368 (2011) (traveling employee; hotel bathroom injury not always arising out of employment; court weights Lord factors)
- Griffith v. City of Miamisburg, 2008-Ohio-6611 (2008) (employee on work-related trip; employer control and benefit considerations; flexibility in analysis)