Zingale v. Maria Heckman & Assoc

In Zingale v. Maria Heckman & Assoc. (July 9, 1998), Cuyahoga App. No. 72914, 1998 WL 382175, a woman employed by a temporary employment agency drove from her assigned workplace to the agency's office to pick up her paycheck. The office consisted of a suite in a multi-suite building. Normally, her paycheck was mailed to her but this time she requested to pick it up, which her employer accommodated. As she walked back to her car, which was parked in a general-use parking lot, to return to work, she slipped and fell and broke her ankle. The employer argued that she was on a personal errand, and therefore, she was not within the scope of her employment. The court, however, found that the injury did not occur on the employer's premises or within the zone of her employment. Rather, she was merely on her way to her place of employment. Consequently, the coming-and-going rule applied to bar compensation for her injury, just like it would apply to an employee injured while commuting from home to her place of work.