In Brown v. Palmer Construction Co, 295 A.2d 263 (Me. 1972) the employees were required to obtain an apartment near the out-of-state worksite for the convenience of their employer. When an exploding stove in the apartment injured the employees, the Law Court held that the employees were entitled to workmen's compensation.
Explaining its decision, the Brown Court stated that the purpose of the Workmen's Compensation Act is "to protect the employee against risks which are not purely self-created but are created by and incidental to the employment." Id. at 266.
The plaintiffs in Brown were entitled to protection where "the injury had its origin in a risk created by the necessity of sleeping and eating away from home." Id. at 267.