Yeldell v. Holiday Hills Retirement and Nursing Center, Inc.
Bertha Yeldell, a vocational nurse for non-subscriber employer Holiday Hills Retirement and Nursing Center, Inc., suffered second and third-degree burns after a coffee urn overturned while she was making a personal telephone call at her duty station. The trial court awarded damages to Yeldell, finding her injuries to be in the course and scope of employment. The court of appeals reversed this judgment. The Supreme Court of Texas reversed the court of appeals, affirming the trial court's decision, ruling that personal telephone calls, like other acts for comfort, can be incidental to employment and thus compensable under the Workers’ Compensation Act. Additionally, the Supreme Court upheld the trial court's exclusion of a witness not disclosed during discovery, stating Holiday Hills failed to supplement interrogatory answers as required by Rule 168(7) of the Texas Rules of Civil Procedure.