Brockway v. Easter

In Brockway v. Easter, 20 Va. App. 268, 456 S.E.2d 159 (1995), the Court stated: To prevail on the defense of a willful violation of a safety rule, employer must prove that: (1) the safety rule was reasonable; (2) the rule was known to the employee; (3) the rule was promulgated for the benefit of the employee; (4) the employee intentionally undertook the forbidden act. Id. at 271, 456 S.E.2d at 161.