Claim of Gabriele v. Educational Bus Transportation, Inc.
The claimant in this case sought workers' compensation benefits after being struck by an automobile during an unpaid lunch break. The incident occurred while he was crossing a public street, having just cashed his paycheck and intending to proceed to a deli. Although a Workers’ Compensation Law Judge initially awarded benefits under a 'dual purpose errand' theory, the Workers’ Compensation Board reversed, ruling that the injury happened outside the scope of his employment. The Appellate Division affirmed the Board’s determination, finding substantial evidence that the claimant's activities ceased to be work-related and became personal once he left the bank, thus making neither the dual purpose nor special errand exceptions applicable.