Alabama: Injuries Sustained During Recreational Horseback Ride Were Not Compensable

Injuries sustained by a Girl Scout camp business manager, when she was thrown from a horse during a recreational ride with other camp employees did not arise out of and in the course of the employment, held an Alabama appellate court. Quoting Larson’s Workers’ Compensation Law, the court agreed with the trial court that the manager failed to show a sufficient connection with the employment to recover. The court noted that the evidence indicated that the employer neither encouraged nor subsidized the activity, that the business manager’s supervisor gave permission to voluntarily participate in the activity in her free time—expressing some concern because of previous problems the manager had with her back—that neither the employer nor its camp supervisors managed or directed the horseback ride, and that there was no evidence that there was any substantial pressure or actual compulsion upon the manager to participate in the ride. Finally, the employer neither expected nor received a benefit from the horseback ride.

Thomas A. Robinson, J.D., the Feature National Columnist for the LexisNexis Workers’ Compensation eNewsletter, is a leading commentator and expert on the law of workers’ compensation.

LexisNexis Online Subscribers: Citations below link to Lexis

See Pollock v. Girl Scouts of So. Ala., Inc., 2015 Ala. Civ. App. LEXIS 43 (Feb. 27, 2015) 

See generally Larson’s Workers’ Compensation Law, § 22.04 

Source: Larson’s Workers’ Compensation Law, the nation’s leading authority on workers’ compensation law.