Epler v. North American Rockwell Corporation

In Epler v. North American Rockwell Corporation, 482 Pa. 391, 393 A.2d 1163 (1978), Franklin M. Epler (Mr. Epler) was employed by North American Rockwell Company (Rockwell) as a foundry worker. Mr. Epler parked his car in a parking lot provided by Rockwell for employees who drove to work. The municipality where Rockwell was located had banned on-street parking near the Rockwell plant and required Rockwell to provide off-street parking for employees. In response, Rockwell established a hierarchy. Rockwell directed management personnel to one parking lot contiguous with the plant and non-management employees, such as Mr. Epler, to an unpaved parking lot located across Park Road. Rockwell issued parking lot permits and limited access to the contiguous parking lot to designated management employees. The evidence established that if any employee violated the parking directive that employee was subject to warnings and disciplinary action for repeated violations. Id. at 394, 393 A.2d at 1164. On May 20, 1972, Mr. Epler completed his work shift shortly after midnight. As he proceeded across Park Road toward his car, which was parked in the designated lot for non-management employees, he was fatally struck by a motor vehicle. Our Supreme Court in Epler framed the issue as whether "the site of the accident was an integral part of employer's premises." Id. at 398, 393 A.2d at 1166. The Supreme Court indicated that the "actual ownership of the area is not necessarily determinative of the question. The Court are satisfied that there are circumstances where an area can properly be designated as 'on the employer's premises' within the meaning of the Act even though the employer is not the legal owner of that area." Id. The Supreme Court concluded that "the critical factor is not the employer's title to or control over the area, but rather the fact that . . . the employer had caused the area to be used by . . . employees in performance of their assigned tasks." Id. at 399, 393 A.2d at 1167.