Idaho Man Injured On Way to Work Eligible for WC
April 29, 2025

The Idaho Supreme Court ruled that an employee was entitled to workers’ compensation benefits under an exception to the coming and going rule because he was operating an employer-provided vehicle at the time, still affirming the decision of the Industrial Commission but taking a different stance as to why. They found him eligible but because his employer intended to compensate him for his travel time to and from work.

Matthew Atkinson worked for 2M Company Inc. as a territorial sales person. Part of his job included taking parts to a client’s business and helping install those parts. He was provided with a 2M pickup truck and would sometimes respond to calls later at night. He had a credit card to purchase gas and vehicle service/maintenance was also covered.

He was on his way to work and noticed he couldn’t see clearly out of his front windshield so he pulled over shortly after leaving his house to scrape the ice off. As he was scraping the windshield he was struck by another car and injured his right leg and shoulder.

Initial hearings determined that he was eligible for compensation because he was in the course of his employment while traveling in an employer-provided car. The Industrial Commission also affirmed benefits, saying that since 2M paid Atkinson for travel time that he was within the course of employment at the time of the accident.

The employer appealed that, and the Idaho Supreme Court still upheld but on different grounds. They felt that the correct exclusion was that Atkinson was driving a company car. They determined that if an employee is injured going to or coming from work and they are in an employer-provided vehicle, that accident is within the course of employment.

Read the case here.

Get the WCInsights Newsletter!