Henry Keim v. Above All Termite & Pest Control

CourtSupreme Court of New Jersey
DecidedNovember 21, 2023
DocketA-30-22
StatusPublished

This text of Henry Keim v. Above All Termite & Pest Control (Henry Keim v. Above All Termite & Pest Control) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Henry Keim v. Above All Termite & Pest Control, (N.J. 2023).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

Henry Keim v. Above All Termite & Pest Control (A-30-22) (087603)

Argued September 11, 2023 -- Decided November 21, 2023

FASCIALE, J., writing for a unanimous Court.

The Court considers whether an employee’s car accident occurred “in the course of employment” under N.J.S.A. 34:15-36’s “authorized vehicle rule” and is therefore compensable under the Workers’ Compensation Act (the Act).

Above All Termite & Pest Control (Above All) employed Henry Keim as a salaried pest-control technician and provided him with an employer authorized vehicle for work use. In compliance with company policy, Keim drove that vehicle in the morning from his own residence to various worksites and returned home in the same vehicle at the end of the workday.

Above All’s policy limited the quantity of supplies technicians could keep in their authorized vehicles overnight. When technicians needed to replenish supplies, Above All authorized them to drive their vehicles to Above All’s shop instead of driving directly to a worksite, to retrieve whatever they required, and then to go from the shop to the scheduled sites. On the morning of the accident, Keim clocked in, received his schedule, and concluded that his vehicle lacked sufficient supplies. On his way to the shop for supplies, Keim sustained injuries in a car accident.

The Judge of Compensation dismissed Keim’s claim petition with prejudice, concluding that Keim was merely commuting to work when he sustained injuries. The Appellate Division applied the “authorized vehicle rule” and reversed the dismissal order. The Court granted certification. 253 N.J. 289 (2023).

HELD: Keim was “in the course of employment” under the “authorized vehicle rule” at the time of the accident because Above All authorized a vehicle for him to operate and his operation of that identified vehicle was for business expressly authorized by Above All.

1. Prior to 1979, broad statutory language defined compensable accidents as those arising out of and in the course of the employment. To distinguish compensable from noncompensable incidents, the courts developed the going and coming rule, 1 which ordinarily precluded an award of compensation benefits for injuries sustained during routine travel to and from an employee’s regular place of work. In 1979, the Legislature amended the Act by defining and limiting the scope of employment. Notably, the Legislature amended N.J.S.A. 34:15-36 to define when “employment” under the Act begins and ends each day. (pp. 9-11)

2. As amended, N.J.S.A. 34:15-36 sets forth four distinct rules that govern when an employee is considered to be “in the course of employment” under the Act: the “premises rule”; the “special mission rule”; the “paid travel time rule; and the “authorized vehicle rule.” That last rule provides that “the employment of . . . any employee who utilizes an employer authorized vehicle shall commence and terminate with the . . . authorized operation of a vehicle on business authorized by the employer.” N.J.S.A. 34:15-36 (emphases added). The “authorized vehicle rule” does not apply every time an employee is driving a vehicle authorized by an employer. And the rule does not categorically apply when an employee is merely commuting to work in either an authorized personal or work vehicle. (pp. 11-16)

3. In this case, Keim argues that his injuries are compensable under the “authorized vehicle rule.” The word “authorized” separates actions that are unrelated to work and thus, not compensable, from actions that are related to work. Based on the plain language of the “authorized vehicle rule” in N.J.S.A. 34:15-36, an employee is “in the course of employment” when (1) the employer authorizes a vehicle for operation by the employee, and (2) the employee’s operation of that identified vehicle is for business expressly authorized by the employer. (pp. 16-18)

4. Under that rule, Keim was in the course of employment when he sustained injuries. Above All provided an authorized vehicle for operation by Keim. Keim’s operation of that vehicle to the shop on the morning of the car accident was solely for business expressly identified and authorized by Above All, namely, to replenish supplies. The permissive approach to replenishment taken here -- whereby employees determined for themselves whether and when to visit the shop on an as needed basis -- does not change the analysis under the language of the authorized vehicle rule. At the time of the accident, Keim was not “merely” commuting to work; rather, he was obtaining needed supplies at a non-worksite location as he was authorized to do by his employer. Because Keim’s injuries are compensable under the “authorized vehicle rule,” the Court does not consider whether any of the other rules established in N.J.S.A. 34:15-36 are applicable here. (pp. 18-20)

AFFIRMED and REMANDED.

CHIEF JUSTICE RABNER and JUSTICES PATTERSON, SOLOMON, PIERRE-LOUIS, WAINER APTER, and NORIEGA join in JUSTICE FASCIALE’s opinion. 2 SUPREME COURT OF NEW JERSEY A-30 September Term 2022 087603

Henry Keim,

Petitioner-Respondent,

v.

Above All Termite & Pest Control,

Respondent-Appellant.

On certification to the Superior Court, Appellate Division.

Argued Decided September 11, 2023 November 21, 2023

Anne Hammill Pasqua argued the cause for appellant (Capehart & Scatchard, attorneys; Anne Hammill Pasqua, of counsel and on the briefs).

April M. Gilmore argued the cause for respondent (The Epstein Law Firm, attorneys; April M. Gilmore, of counsel and on the brief).

Richard B. Rubenstein argued the cause for amicus curiae New Jersey Advisory Council on Safety and Health (Rubenstein, Berliner & Shinrod, attorneys; Richard B. Rubenstein, of counsel and on the brief).

JUSTICE FASCIALE delivered the opinion of the Court.

1 In this workers’ compensation case, we determine whether an

employee’s car accident occurred “in the course of employment” and is

therefore compensable under the Workers’ Compensation Act (the Act),

N.J.S.A. 34:15-1 to -147.

In N.J.S.A. 34:15-36, the Legislature expressly defined when

employment commences and terminates in different settings or scenarios. It

created what are generally known as the “premises rule”; the “special mission

rule”; the “paid travel time rule”; and the “authorized vehicle rule.” In this

case, petitioner Henry Keim argues that he is entitled to compensation for his

injuries under the statute’s “authorized vehicle rule.” To assess his eligibility

under N.J.S.A. 34:15-36, we examine the statutory meaning of operating an

“employer authorized vehicle” to conduct “business authorized by the

employer.”

We hold that an employee is “in the course of employment” under the

“authorized vehicle rule” prescribed by N.J.S.A. 34:15-36 when (1) the

employer authorizes a vehicle for operation by the employee, and (2) the

employee’s operation of that identified vehicle is for business expressly

authorized by the employer. Here, consistent with the “authorized vehicle

rule,” the employer, Above All Termite & Pest Control (Above All), provided

a vehicle and authorized the employee, Keim, to operate that vehicle to

2 replenish supplies at a particular location as needed. Keim was thus “in the

course of employment” when he drove his authorized vehicle to obtain the

supplies and was injured in a serious car accident. As a result, he is entitled to

benefits under the Act.

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Henry Keim v. Above All Termite & Pest Control, Counsel Stack Legal Research, https://law.counselstack.com/opinion/henry-keim-v-above-all-termite-pest-control-nj-2023.