Novis v. Rosenbluth Travel

In Novis v. Rosenbluth Travel, 138 N.J. 92, 649 A.2d 69 (1994), petitioner, who was employed as a reservationist, occasionally was required to work at off-site locations. At the time of the accident, she was temporarily working in her employer's Connecticut branch office. The office was located in a building in which there were many tenants, only one of which was petitioner's employer. There was a parking lot across the street from the building in which the tenants' employees and visitors could park. There is no indication, however, that such parking was by employer designation. Petitioner was injured after she parked her car in the lot and was crossing the street to the building. Concluding that the facts were insufficient to establish any exercise of control by the employer over the lot or the access/egress route, the Court concluded that petitioner's accident did not occur within the premises rule and that at the time of the accident she had not yet commenced her employment. 138 N.J. at 96, 649 A.2d 69.