Kohlmayer v. Keller

In Kohlmayer v. Keller (1970), 24 Ohio St.2d 10, 263 N.E.2d 231, the employee was injured at a social event. The employer sponsored, supervised, and financed the event at his home. Its primary purpose was to improve employee relations. Attendance was voluntary, it was held during non-work hours, and no business was conducted. The employee broke his neck while using the provided swimming facilities. The Court found that attendance at the event was consistent with the employment contract and logically related to employment. The employer's involvement meant that the event was not merely social but also existed to improve the employer's business, which did benefit, said the Court. Therefore, there was a sufficiently strong connection between the activity and employment that the injury was received in the course of employment.