Campbell v. Industrial Commission

In Campbell v. Industrial Commission, 165 Ariz. 583, 586, 799 P.2d 1357 (App. 1990), a ranch hand was injured while on his way into town to perform some personal errands and to purchase several items for his employer at a hardware store. The employer testified the items requested were not urgently needed, they were not important enough for a special trip, and he doubted the employee would have been sent for them if he were not traveling to town on personal business. Id. at 585. The employee acknowledged "he would have taken the trip even if there had not been a business purpose for it." Id. at 585-86. Despite these facts, the ALJ concluded that the employee's claim was compensable because the injury occurred during a trip that served both a business and personal purpose. Id. at 586. On appeal, this court vacated the award, holding that a special trip would not have been undertaken by the employee for the hardware items because someone else could have done it at another time without the need for a special trip. Id. at 588.