According to Law360, the Pennsylvania justices ruled that the state's “traveling employee doctrine” applied to the situation, and the Cintas employee, Jonathan Peters, was on the job at the happy hour event, unless Cintas could prove that he wasn’t. This was applied even though the work-sponsored happy hour was voluntary. The Supreme Court’s ruling was unanimous and it overturned a 2019 ruling from Pennsylvania’s Commonwealth Court.
“The record reflects that employer hosted and sponsored the event,” wrote Justice Sallie Updyke Mundy in the court’s opinion, which was decided on Nov. 17. “While work may not have been discussed at the event, the event still benefited employer by fostering relationships and improving morale.”
Pennsylvania’s Superior Court created the traveling employee doctrine, which says workers are given the benefit of the doubt that travel is part of work responsibilities. But this case, Peters v. Workers’ Compensation Appeal Board, is the first time the state’s Supreme Court has ever addressed the doctrine.
Mundy wrote that Peters’ case applied to the traveling employee doctrine because he had to travel to perform his job earlier in the day, which overturned the initial worker’s compensation ruling that denied Peters compensation. Additionally, since Cintas organized and paid for the happy hour event, which was done for the company’s benefit, it was ruled to be within the scope of Peters’ employment, even though attendance for the event wasn’t required.
Counsel for Peters and Cintas didn’t respond to request for comment to Law360.
According to Montgomery County law firm Hamburg, Rubin, Mullin, Maxwell & Lupin, this decision will likely have ramifications for businesses’ work-related events, like happy hours. According to a blog post from the law firm, employers and insurance providers will need to take into account events like happy hours when determining coverage limits, costs, and premiums.