Case Law Database

Douglas Skubitz (Deceased) vs. Hanford Community Hospital, Adventist Health

This case involved the compensability of a fatal work injury sustained by Douglas Skubitz while traveling to a company conference. The Workers' Compensation Appeals Board affirmed the finding that Skubitz's death arose out of and occurred in the course of employment, rejecting the employer's "going and coming" rule defense by applying the special mission and commercial traveler exceptions. The Board also reversed the initial finding, determining that Skubitz's newborn granddaughter, Emilia Wood, was his total dependent at the time of his death. A dissenting opinion argued that Emilia was not a dependent due to the speculative nature of support and her father's legal obligation.