Louisiana: Police Sergeant’s Short Trip to Headquarters To Get Cash From Credit Union Was Deviation From Employment; Injuries in Stairwell Not Compensable

A Louisiana appellate court recently affirmed the denial of a claim filed by a police sergeant who sustained injuries when he fell in a stairwell at Police Headquarters following a visit to a credit union to get cash [Ruiz v. City of New Orleans, 12–405 (La.App. 5 Cir. 01/16/13), 2013 La. App. LEXIS 75]. The sergeant was assigned to the Communications Division, which was located in a building some blocks away from Police Headquarters. He sustained his injuries as he was leaving the Headquarters building after visiting the credit union. The City denied his claim, contending that the injuries did not occur in the course and scope of the employment. The WCJ agreed and the sergeant appealed.

The sergeant contended that his injuries occurred during the course and scope of his employment since he had completed his personal errand and was returning to work. The appellate court disagreed. NOPD Headquarters was not and had not ever been his assigned worksite. The court indicated that he was on a personal errand with the express permission of his supervisor but he had not been requested, directed, instructed or required by his employer to travel from the Communications Division to NOPD Headquarters. The errand was not employment related.