When do parking lot accidents qualify for workers' compensation benefits? IHG v. Labor Comm'n Explained

In IHG v. Labor Comm’n, the Utah Supreme Court clarified important principles governing workers’ compensation coverage for parking lot accidents, providing crucial guidance for practitioners handling premises liability issues in workers’ compensation cases.

Background and Facts

Jessica Wilson suffered a severe injury when she slipped and fell in a parking lot adjacent to her employer IHG’s office building while walking to work. The fall resulted in foot injuries requiring two surgeries and amputation of her third toe. Although IHG did not own the parking lot, it had “nonexclusive rights” to use the entire lot and “exclusive parking rights” to certain spaces, paying the landlord’s maintenance costs. IHG’s workers’ compensation carrier denied Wilson’s claim under the going-and-coming rule, arguing the accident did not arise out of and in the course of her employment.

Key Legal Issues

The court addressed two fundamental workers’ compensation requirements: whether Wilson’s accident (1) arose out of her employment, and (2) occurred in the course of her employment. IHG argued the accident failed both tests because it involved risks common to the general public and occurred while Wilson was merely traveling to work.

Court’s Analysis and Holding

The Supreme Court rejected IHG’s arguments on both prongs. For the “arising out of” requirement, the court held that legal causation is satisfied when employment is “a condition out of which the event arises,” even in unexplained falls. Wilson’s particular injury would not have occurred where and when it did but for her employment obligation to report to work. For the “in the course of” requirement, the court clarified that the going-and-coming rule applies only to off-premises accidents. When an accident occurs on the employer’s premises, no additional analysis is required—the employee is automatically considered to be in the course of employment.

Practice Implications

This decision provides a bright-line rule for premises-based accidents: if an employee is injured on the employer’s premises, the going-and-coming rule does not apply, and the Jex factors need not be considered. The court also confirmed that parking lots used by employees with employer consent constitute part of the employer’s premises, regardless of ownership. This significantly expands potential workers’ compensation coverage for parking lot accidents and clarifies that the focus should be on the employer’s control over or interest in the parking area rather than formal ownership.