The New Jersey Supreme Court ruled on February 8, 2021, that Kim Goulding is entitled to worker's compensation for injuries sustained while volunteering at an employer-sponsored event. This decision affects employees who may be injured during similar activities and clarifies the interpretation of the state's Worker’s Compensation Act.
Goulding worked for North Jersey Friendship House, a non-profit organization focused on assisting individuals with developmental disabilities. On September 23, 2017, she volunteered to help at the organization’s first-ever Family Fun Day, an event designed to provide recreational activities for clients and their families. While preparing lunch at the event, she fell and injured her ankle. After her claim for worker's compensation was initially dismissed, the Supreme Court's ruling reversed that decision, allowing her to pursue benefits.
The case, Kim Goulding v. NJ Friendship House, Inc. (A-48-19), began when Goulding filed a claim for worker's compensation after her injury at the Family Fun Day. Friendship House argued that her injury was not compensable because it occurred during a social or recreational activity. The workers’ compensation court agreed, stating that the event was social in nature and that Goulding was not performing her work duties at the time of the injury.
The Appellate Division upheld this decision, leading Goulding to appeal to the New Jersey Supreme Court. The court's ruling focused on whether Family Fun Day constituted a social or recreational activity under New Jersey's Worker’s Compensation Act, specifically N.J.S.A. 34:15-7, which generally excludes compensation for injuries sustained during such activities unless certain exceptions apply.
Justice Fernandez-Vina, writing for the court, stated, "The injury sustained by Kim Goulding while volunteering at her employer-sponsored event is compensable because, as to Goulding, the event was not a social or recreational activity." The court emphasized that the nature of Goulding's role at the event was crucial in determining compensability. Since she was performing her job duties by cooking for the event, the court found that her injury was a regular incident of her employment.
The court also noted that Family Fun Day served a purpose beyond just improving employee morale. It was an outreach event aimed at benefiting the clients of Friendship House, which created goodwill in the community and could enhance future fundraising efforts. Therefore, the court ruled that Goulding's injury met the two-prong test for compensability under the Worker’s Compensation Act.
This ruling has significant implications for employees working in non-profit sectors and those involved in employer-sponsored events. It clarifies that injuries sustained during such events can be compensable if the employee's role aligns with their job responsibilities and if the event serves a broader purpose that benefits the employer.
The court's decision also addresses the ambiguity surrounding what constitutes a social or recreational activity, emphasizing that the focus should be on the employee's role rather than the event's overall nature. This interpretation encourages employees to participate in employer-sponsored events without fear of losing compensation rights in case of injury.
Looking ahead, the ruling sets a precedent for future cases involving worker's compensation claims related to employer-sponsored events. It reinforces the idea that the Worker’s Compensation Act should be interpreted liberally to protect employees and ensure they receive benefits for work-related injuries.
As for next steps, Friendship House may consider appealing the decision, but details regarding any potential appeal were not available in the court filing. There are no related cases pending that directly address this issue at the moment.