A woman who was working from home tripped over her dog when she went to get her coffee cup in her kitchen. She sought workers’ compensation benefits but was denied on the basis that her injury did not arise out of her employment.

Tammitha Valcourt-Williams was a claims adjuster for Sedgwick and could work from home. She was working one day for about three hours and went downstairs to get a cappuccino. She was reaching for a cup and tripped over one of her two dogs, injuring her knee, hip and shoulder.

She had a work-from-home arrangement with her employer and her injury occurred during work hours, so she sought benefits. Sedgwick initially denied the claim because her claim did not arise out of her employment with them. A Judge of Compensation Claims agreed with her side of the case initially. They determined that her work-from-home arrangement meant that her employer “imported the work environment into the claimant’s home and the claimant’s home into the work environment.”

Sedgwick appealed, and it was agreed that her injury occurred in the course and scope of her employment because she was injured during work hours, home was where she would reasonably be, and her coffee break was a permissible comfort break. At issue was whether or now the injury arose out of her employment.

The Court decided that an accidental injury arises out of employment only if the work performed was the major contributing cause of the injury. This accident was not compensable because her employment did not expose her to conditions that would contribute to the risk of injury and it wasn’t a condition that she would not have normally been exposed to outside of work. They determined she could have tripped at home even if she was not working for this particular employer so there was no occupational causation.

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