The Texas Court of Appeals ruled that a worker, who had been out on his lunch hour but was expected to attend a mandatory training at an offsite location after his lunch hour, was within the course and scope of his employment when he was injured in a car accident.

Juan Carolos Pena worked for the Texas Health and Human Services Commission (HHSC) and was injured in a car accident at 12:06 pm. He worked in an office in McAllen, TX but the training was scheduled at the Edinburg, TX facility at 1:30 p.m. The State Office of Risk Management (SORM) challenged his guardian’s request for benefits, saying that the accident occurred during his lunch hour which was uncompensated. HHSC employees had a normal lunch hour of 12-1:00 p.m., and they were allowed to leave the office though the hour was not compensated. The commission had provided him thirty minutes of compensated travel time beginning at 1:00 p.m. to get to the training on time. Pena was directed to attend the training by his supervisor and it was mandatory. He and fellow employees were released at noon in order to attend the training at 1:30. No workers returned to the office after lunch before leaving to attend the training. Pena had allegedly taken the quickest route.

Initially Arnold Pena (his guardian) requested workers’ compensation benefits but was denied by a hearing office and administrative appeals panel. In court, SORM argued that he was not within the course and scope of his employment at the time of the incident and his injuries were not compensable when it came to the case of his resulting disability. They questioned where he was going at the time of the accident. Arnold Pena argued that his travel at the time was for a “dual purpose”. A jury determined his injury was compensable and established that his disability was the result of his compensable injury. SORM appealed. The Texas Court of Appeals determined that he was within the course and scope of his employment, as he was doing something that would further the interest of his employer by attending a training.

Read the case here.