Coleman v. Armour Swift-Eckrich

281 Kan. 381, 130 P.3d 111 (2006)

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Coleman v. Armour Swift-Eckrich

Kansas Supreme Court
281 Kan. 381, 130 P.3d 111 (2006)

Facts

Christie Coleman (plaintiff) was employed by Armour Swift-Eckrich (Armour) (defendant). While waiting for the start of a meeting that she was required to attend, Coleman sat on a chair with rollers and had her feet propped on another chair. A coworker came up behind Coleman and, in a playful manner, grabbed the back of Coleman’s chair and dumped her onto the floor. There was no evidence that such horseplay was common at Armour and no evidence that Armour had condoned the coworker’s actions. Coleman’s back was injured in the fall, and an administrative-law judge (ALJ), relying on longstanding precedent, denied Coleman’s claim for workers’-compensation benefits, finding that the horseplay that caused the injury did not arise out of and in the course of Coleman’s employment. The workers’-compensation review board affirmed, and Coleman appealed.

Rule of Law

Issue

Holding and Reasoning (Beier, J.)

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