Claim of Marquis v. Frank's Vacuum Truck Service, Inc.
A claimant, a truck driver, appealed a Workers’ Compensation Board decision denying his claim for benefits after sustaining a gunshot injury to his left knee during a lunch break. The Board had ruled that the injury was not causally related as the claimant had substantially deviated from his employment at the time of the incident. Evidence presented indicated the claimant had previously been warned by his employer not to return to the area where the attack occurred due to a prior incident. Furthermore, his actions post-injury, such as driving away and attempting to prevent bystanders from calling the police, supported the Board's conclusion of a deviation. The Appellate Division affirmed the Board’s decision, finding substantial evidence to support the determination that the claimant was outside the scope of his employment.