Haase v. City of Buffalo

In Haase v. City of Buffalo (255 AD 357 [4th Dept 1938]) an employee of the Buffalo Department of Parks struck and fatally injured an individual while the employee was driving to a restaurant "to procure an emergency meal" because "the requirements of his employment that day had prevented him from having his usual evening meal." (255 AD at 360.) The court concluded that "food was necessary for the continuance of the employee's work" and that "he did not step out of his employment' " when he went to purchase his meal. (Id.)