Provident Life & Accident Ins. Co. v. Barnard
In Provident Life & Accident Ins. Co. v. Barnard, 236 Va. 41, 372 S.E.2d 369 (1988), the Virginia Supreme Court extended compensation to situations where the employer "agrees to provide the employee transportation by company vehicle or public conveyance; or to pay the employee wages or salary for the time spent in travel required by the work; or to reimburse the employee expenses incurred in the operation of his own vehicle in the performance of his duties." Id. at 47, 372 S.E.2d at 372-73.
See also Cardillo v. Liberty Mut. Ins. Co., 330 U.S. 469, 482-83, 91 L. Ed. 1028, 67 S. Ct. 801 (1947) ("Where there is that obligation to provide transportation, it becomes irrelevant in this setting whether the employer performs the obligation by supplying its own vehicle, hiring the vehicle of an independent contractor, making arrangements with a common carrier, reimbursing employees for the use of their own vehicles, or reimbursing employees for the costs of transportation by any means they desire to use.").