Ruckman v. Cubby Drilling, Inc

In Ruckman v. Cubby Drilling, Inc. (1998), 81 Ohio St.3d 117, 119, 1998 Ohio 455, 689 N.E.2d 917, the Ohio Supreme Court stated that a fixed-situs employee can avoid the force of the coming-and-going rule if she can otherwise demonstrate that she received her injury in the course of and arising out of her employment. Ruckman, supra at 120, citing MTD Products, 61 Ohio St.3d 66, 572 N.E.2d 661. Accordingly, the rule does not operate as a complete bar to an employee who is injured commuting to and from work if: (1) the injury occurs within the 'zone of employment; (2) the employment creates a 'special hazard,' or; (3) there is a causal connection between the employee's injury and employment based on the 'totality of the circumstances' surrounding the accident." Weiss v. Univ. Hosp. of Cleveland (2000), 137 Ohio App.3d 425, 430-431, 738 N.E.2d 884.