Williams v. New York State Department of Health
The claimant was injured while rollerskating during her lunch hour on the Empire State Plaza mall. She sought workers' compensation benefits, asserting that her rollerskating was part of an employer-sponsored smoking cessation program that encouraged physical activity. The employer, State Department of Health, and its insurance carrier contested the claim, arguing it was a personal activity. The Workers’ Compensation Board denied benefits, concluding that the injuries did not arise out of and in the course of her employment. On appeal, the court affirmed the Board's decision, finding sufficient evidence that her rollerskating was a voluntary, personal act unrelated to her employment, as the cessation program had no physical exercise component.