Santa Rosa Junior College v. Workers’ Compensation Appeals Board

Joseph Smyth, a mathematics instructor and department head at Santa Rosa Junior College (college) (plaintiff), was killed in an automobile accident on his way home from work. Smyth’s widow sought a workers’-compensation death benefit. At the time of the accident, Smyth was driving his personal automobile and had student papers with him that he intended to grade that evening. Smyth regularly graded papers and prepared lessons at home in order to minimize interruptions from students and to spend more time with his family. As head of the mathematics department, Smyth was responsible for certain administrative work, including receiving telephone calls on behalf of the department; these calls often interrupted his grading and class-preparation work. At home, Smyth worked in a dedicated space in the living room, where he kept duplicate copies of necessary books. The college neither encouraged nor discouraged taking work home. A workers’-compensation judge concluded that Smyth’s death did not occur in the course of his employment because Smyth had adequate facilities and sufficient time to complete his work on campus and because it was Smyth’s choice to take work home. The Workers’ Compensation Appeals Board (board) (defendant) reversed, reasoning that Smyth’s work from home was more of a business necessity than a personal convenience. Specifically, the board found that Smyth was essentially required to maintain a second worksite in his home, that he was implicitly authorized to perform part of his duties at home, and that this was an implied term or condition of his employment. The college sought judicial review of the board’s decision.