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Substantial evidence supported the factual finding that employee’s injury arose out of and in the course of his employment where employee, who was on a business trip, was injured in a car accident following a social but business-related dinner where alcohol was consumed.
Hall was a Desert Aire National Sales Manager. He traveled approximately 4 days a week during the course of his job. His injury occurred while he was on a business trip to Arkansas. Alcohol and entertaining social events were customary and a part of Hall’s job. While in Arkansas, Hall had dinner with Brunner, an agent with Airtech (a company that sold Desert Aire products) and several other people. At the dinner, alcohol was consumed and business was discussed. Later in the evening, Brunner and Hall took Brunner’s Jeep for a drive. Brunner, the driver, was killed when the Jeep overturned. Hall was injured and required hospitalization. Hall sought Workers’ Compensation benefits for his injuries. Desert Aire alleged that Hall’s injury did not arise out of and in the course of his employment.
The Commission and the Circuit Court found Hall’s injuries compensable. The Court of Appeals affirmed compensability under the standard set forth in S.C. Code § 42-1-160. Hall’s employment was a contributing proximate cause of his accident and his resulting injuries arose out of his employment. The evening’s activities were logically related to Hall’s employment responsibilities. His purpose of traveling to Arkansas was to conduct business. Hall and Brunner continued to discuss business when they took the Jeep for a drive. There was substantial evidence to support the finding that the alcohol consumed did not render Hall and Brunner unable to engage in business discussions. Furthermore, the record demonstrated that Hall was engaged in ongoing discussions regarding planning for sales activities at the time of the accident. The accident occurred within the period of employment at a place where Hall was reasonably in the performance of his duties or engaged in activities incidental to his employment. He was not exercising a personal privilege wholly apart from Desert Aire’s interests.
