Can a Detective Who Gets Accidently Injured by His Service Revolver After the End of His Work Shift Claim Compensation ?
In City of Harrisburg v. Workmen's Comp. Appeal Bd. (Gebhart), 532 Pa. 592, 616 A.2d 1369 (1992), the Supreme Court reversed this Court's decision and held that a police detective who was injured when he accidentally discharged his service revolver while unholstering it at his home, after the end of his work shift, was compensable.
The Court set forth the two-part requirement that the injury must occur in the course of employment and be related thereto, and that in making that determination, it "must ascertain whether Claimant was actually engaged in the furtherance of Employer's business when the off-premises injury occurred." Id. at 597, 616 A.2d at 1371.
The Court held that a paramount part of an officer's job is to secure and store his service revolver after the work shift ends.
The Supreme Court, in City of Harrisburg, extended benefits to a claimant who was not necessarily "on the clock" when the injury took place but, nevertheless, was found to be in the course of employment at the time of the injury.
See also Krawchuk v. Philadelphia Elec. Co., 497 Pa. 115, 439 A.2d 627 (1982) (finding a fatal heart attack occurring at home to be compensable because decedent suffered unusual stress and pressure relating to his course of employment).