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Injuries Sustained At The End Of A Workday Are Still Compensable Under the Workers’ Compensation Act (NJ)

February 18, 2022

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<p style="text-align: justify;">In<em> <a href="https://www.wcmlaw.com/wp-content/uploads/2022/02/Diane-S.-Lapsley-v.-Township-of-Sparta.pdf">Diane S. Lapsley v. Township of Sparta</a></em>, defendants appealed from a denial of workers’ compensation benefits to plaintiff under the Workers Compensation Act. Plaintiff was employed as a librarian for the Sparta Public Library by the Township. After leaving the library at the end of her workday and while walking through the parking lot to her car, plaintiff was struck and injured by a snowplow owned and operated by the Township. The Township owned and maintained the parking lots, which were open to both its employees and the public. Township employees were not directed nor required to park in the parking lots.</p>
<p style="text-align: justify;">On appeal, the Supreme Court of New Jersey held that plaintiff was still entitled to compensation benefits. The court reasoned that her injuries occurred prior to the end of her workday because the subject accident occurred in a parking lot owned and controlled by the Township, and she had not yet left the premises following the end of her shift.</p>
<p style="text-align: justify;">The Court’s ruling expands the applicability of the Workers Compensation Act with respect to compensation benefits. Entitlement to compensation benefits is not narrowly construed to just injuries sustained during a work shift but can now be available even after an employee “clocks out” for the day – so long as the injury occurs on the employer’s premises.</p>
<p style="text-align: justify;">Thanks to Gina Rodriguez for her contribution to this article.  If you have any questions, contact <a href="mailto:mcare@wcmlaw.com">Matthew Care</a>.</p>

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