In American Management Systems, Inc. v. Burns, 1995 OK 58, 903 P.2d 288, an employee traveled to Oklahoma to install computer software. During his time in Oklahoma, he checked into a local motel of his choice and was robbed and murdered at the motel.
The Oklahoma Supreme Court determined that the murder occurred in the course of his employment, because he had traveled to Oklahoma as a work assignment. Id. at 291.
The court found, however, that the murder did not arise out of his employment. Id. The court noted that an injury arises out of employment where it results from a risk which is reasonably connected to an assigned task. Id.
The court found that the legislature had abandoned the "unknown assailant rule," which had previously allowed compensation for an attack by an unknown assailant occurring while the claimant was on the job and working. Id. at 292.
The court concluded that there was no evidence that the risk of attack to the worker in Burns was greater than the risks encountered by the general public using lodging similar to that selected by the worker. Id. at 293.