Barnes v. Stokes

In Barnes v. Stokes, 233 Va. 249, 252, 355 S.E.2d 330, 331 (1987), the claimant was struck by a motor vehicle operated by a fellow employee in a private parking lot adjacent to their place of employment. Id. at 250, 355 S.E.2d at 330. The lot was neither owned nor maintained by the employer, but the employer was allocated a portion of the lot, which accommodated all of its employees, and directed its employees to park in the designated area. Id. at 251, 355 S.E.2d at 331. In finding that the claim was compensable, the Supreme Court of Virginia held: the injury occurred in an area specifically allocated to the employer at a place where the employees were required to park their vehicles; the claimant's injury was sustained while she passed to her work, with the consent of the employer, over the premises of another "'in such proximity and relation as to be in practical effect a part of the employer's premises.'" Barnes, 233 Va. at 252-53, 355 S.E.2d at 331-32.