Intercontinental Hotels Group v. Utah Labor Commission

2019 UT 55, 448 P.3d 1270 (2019)

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Intercontinental Hotels Group v. Utah Labor Commission

Utah Supreme Court
2019 UT 55, 448 P.3d 1270 (2019)

Facts

Jessica Wilson worked for Intercontinental Hotels Group (IHG) (plaintiff). One morning, on Wilson’s way to work, she tripped and fell in a parking lot next to IHG’s office building. IHG did not own the lot, but IHG employees frequently used the lot. Wilson seriously injured her foot in the fall, and Wilson sought workers’-compensation benefits. IHG’s workers’-compensation provider denied Wilson’s claim based on the conclusion that Wilson’s injury had not arisen out of and in the course of Wilson’s employment, as required to receive workers’-compensation benefits under Utah law. Wilson challenged the denial of benefits with the Utah Labor Commission (the commission) (defendant). The commission determined that the parking lot where Wilson fell was part of IHG’s premises and that Wilson was entitled to benefits because the accident had arisen out of and in the course of Wilson’s employment. IHG sought review of the commission’s determination in the Utah Court of Appeals, arguing that (1) the accident did not arise out of Wilson’s employment because Wilson’s injury did not result from an employment-related risk, and (2) the accident did not occur in the course of Wilson’s employment because Wilson was traveling to work when the accident occurred. The appellate court certified the case to the Utah Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Durrant, C.J.)

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