State Supreme Court Ruling Expands “Traveling Employee Doctrine” to Include Employer Sponsored Happy Hours

A recent ruling from the Pennsylvania Supreme Court significantly expands employers’ workers compensation liability. Will it mean the end of office happy hours and office holiday gatherings?


The case, Peters v. Workers Compensation Appeals Board, centers on injuries sustained in a car crash by a traveling salesperson for Cintas Corporation following a work-sponsored happy hour. In a unanimous decision, the court ruled that the situation fell under Pennsylvania’s “traveling employee doctrine.” The doctrine specifies that “workers are given the benefit of the doubt that travel is part of work responsibilities.” By applying this doctrine, the court held that the worker was covered for workers compensation for injuries sustained in the accident, despite the social event being voluntary.   

Justice Sally Updyke Mundy wrote in the court’s opinion that “The record reflects that employer hosted and sponsored the event. While work may not have been discussed at the event, the event still benefited employer by fostering relationships and improving morale.” 

Legal experts warn that the court’s decision could have an impact on employer sponsored events, as well as the scope of insurance coverage employers will need to obtain. 

The Supreme Court’s ruling overturns a previous state Superior Court decision. 

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