Workers’ Compensation Benefits Were Due to Plaintiff, Under the “Premises Rule”

Lapsley v. Sparta Tp., ___ N.J. ___ (2022). As discussed here, this Workers’ Compensation Act case was one in which plaintiff, a librarian at the Sparta Public Library, was walking through a parking lot owned by the Township to where her husband, who had come to pick her up, had parked their car. She was hit by a snowplow owned by the Township and driven by a Township employee. She sued for Workers’ Compensation benefits, and the Division of Compensation agreed that she should receive them. The Township appealed, and the Appellate Division reversed.

Today, however, the Supreme Court reversed that ruling in a unanimous opinion by Justice Fernandez-Vina that recognized the need to give deference to the Judge of Compensation unless the judge’s factual findings and legal determinations were “manifestly unsupported by or inconsistent with competent relevant and reasonably credible evidence as to offend the interests of justice.” After discussing generally the intent and background of the Workers’ Compensation system, Justice Fernandez-Vina focused on the “premises rule,” which was added in 1979 amendments. “The premises rule is based on the notion that an injury to an employee that happens going to or coming from work arises out of and in the course of employment if the injury takes place on the employer’s premises.”

Here, the injury occurred in a parking lot that the Township controlled “through its ownership and maintenance.” There was no dispute about that. “The Township’s plowing of the parking lot of snow when the accident occurred visibly demonstrated the Township’s exercise of control over the lot. [Citation]. Also, the Township would have been aware that a library employee would park in the lot directly abutting the library.” Accordingly, under the premises rule, plaintiff was entitled to benefits.