In Hunton & Williams v. Gilmer, 20 Va. App. 603, 460 S.E.2d 235 (1995), the claimant slipped and fell on ice that accumulated in a parking garage across the street from the employer's premises. The employer did not own or maintain the parking garage. Id. at 604, 460 S.E.2d at 235. The garage was owned by the employer's landlord. The claimant paid to park in the garage. Id. at 604-05, 460 S.E.2d at 235. The employer did not require its employees to park in the garage. Id. at 605, 460 S.E.2d at 235. The claimant paid for her parking privileges through a payroll withdrawal because the employer was required to pay the garage fee for its employees by one check. Id. at 604-05, 460 S.E.2d at 235-36. The employer, however, did not receive a discount for the parking fees and did not subsidize the cost of parking of its employees. Id. at 605, 460 S.E.2d at 236. No evidence established that the employer's workers were assigned to a particular location within the garage. Id.