Dorman v. Carroll County

1 Citing case

  1. Seaman v. Burgess Health Ctr. & Farm Bureau Mut. Ins. Co.

    872 N.W.2d 198 (Iowa Ct. App. 2015)

    The dual purpose exception applies when an employee is injured off the employer's premises while making a trip that serves both personal and business purposes. See Golay, 175 N.W.2d at 388 (affirming workers' compensation benefits for employee who was on a trip which combined a special errand of “sufficient substance” for his employer and a non-compensable purpose); Dorman v. Carroll Cnty., 316 N.W.2d 423, 424–25 (Iowa Ct.App.1981) (finding dual purpose doctrine applied when two deputy sheriffs on auxiliary duty were killed, while driving under the influence to breakfast from their law enforcement duty). “ ‘Injury during a trip which serves both a business and a personal purpose is within the course of employment if the trip involves the performance of a service for the employer which would have caused the trip to be taken by someone even if it had not coincided with the personal journey.’ “ Golay, 175 N.W.2d at 388 (quoting 1 Larson, The Law of Workmens' Compensation, 294.3, § 18.00 (1965)).