Cardillo v. Liberty Mutual Insurance

Background

A construction electrician who lived in the District of Columbia was assigned to a multi-year job at the Quantico Marine Base in Virginia. His employer paid a $2 daily transportation allowance under a union agreement instead of supplying vehicles. Workers formed a car pool to reach the distant job site. After work one day the electrician was driving home in that car pool when a stone from a passing truck smashed his windshield and later caused his death; his widow filed for compensation.

Reasoning

The Court first held that the compensation officer had authority to decide the claim because the worker was a District resident employed by a District employer and had substantial ties to the District. The Court then explained that courts must generally defer to the administrative officer’s factual inferences when supported by evidence. It discussed the usual rule that commuting injuries are not work injuries but noted recognized exceptions. Applying the exception for employers who contract to furnish transportation, the Court found the employer’s payment of the travel allowance was simply one way of fulfilling that obligation, so the fatal trip was part of the job.

Real world impact

The decision means employees who commute under arrangements the employer agrees to or pays for may receive workers’ compensation for accidents during those trips. An employer’s choice to reimburse workers rather than provide a vehicle does not automatically block a claim. The ruling narrows when courts may overturn reasonable agency findings supported by the record.

Dissents or concurrances

Two Justices dissented and one Justice agreed only in the result; the opinion does not detail their separate arguments.