Ohio Nurse’s Fall in Hospital ER Was Outside Course and Scope of Employment

A hospital nurse, who fractured her humerus in a fall in her employer’s emergency room when her coat apparently became ensnarled in a wheelchair, did not sustain an injury arising out of and in the course of the employment, held an Ohio appellate court [see Power v. Bay Park Community Hosp., 2015 Ohio 1272, 2015 Ohio App. LEXIS 1181 (Mar. 31, 2015)]. Noting that the nurse had actually clocked out for the day and had walked to the emergency room to retrieve a friend who had been treated and discharged there, the court held the nurse failed to establish the necessary causal connection between the injury and the workplace. The nurse had acknowledged that she did not ordinarily traverse the emergency room either going to or from her work at the hospital. The court concluded, therefore, that at the time of the nurse’s fall she was not under the direction of her employer and the employer/hospital received no benefit from the nurse’s presence in the ER.