Anowai v. Holiday Inn
Claimant, a security officer, was struck on the head by falling facade debris from an adjacent building shortly after completing his shift at a Manhattan hotel. He filed for workers' compensation benefits, and a Workers’ Compensation Law Judge initially ruled the accident arose out of and in the course of employment, deeming it within the area of egress. However, the Workers’ Compensation Board reversed this decision, concluding that the accident did not occur as an incident or risk of employment because it happened on a public street, in front of a separate building, and involved a hazard outside the employer's control. The appellate court affirmed the Board's decision, finding no basis to overturn its factual findings regarding the nexus between the accident and the claimant's employment. The court reiterated that while risks near the employment situs can merge with employment risks, the Board's discretionary determination of such risks should be respected.