Peterson v. Industrial Commission
In Peterson v. Industrial Commission, 16 Ariz. App. 41, 490 P.2d 870 (1971), a traveling employee spent several hours drinking, conversing, and playing pool before retiring for the evening in a nearby rooming house.
He then suffocated to death after his head became stuck in the slats of the headboard as he slept.
The Peterson court stated that an injury occurs in the course of employment "if the employee is injured while he is doing what a man so employed may reasonably do within a time during which he is employed and at a place where he may reasonably be during that time." Id. at 44, 490 P.2d at 873.
The court held that the claim was compensable because "a reasonable period of sleep is necessarily incidental to the work of a traveling employee required to take overnight lodging away from his home." Id.