Chapman v. Meyers

In Chapman v. Meyers, 899 P.2d 48 (Wyo. 1995), the claimant Chapman commuted daily with three co-employees from a motel in Craig, Colorado, to their work site, a drilling rig. Id. at 50. The opinion does not disclose whether or not the employer paid for the motel accommodations. Neither Chapman nor his co-employees were reimbursed for travel to and from the drill site or paid a travel allowance as part of their wages. Id. After finishing his shift, Chapman left the drill site in a vehicle owned by the wife of a co-employee. Id. The road from the drill site was a snow-packed, two-lane, graveled public road through a mountainous area. Id. Approximately one mile from the drill site, the vehicle collided head-on with a truck, resulting in severe injuries to Chapman. Id. The hearing examiner determined that Chapman was not in the course and scope of his employment and was, therefore, denied benefits. Id. at 49. On appeal, Chapman contended that his employer "required, and contemplated" that its employees would not be able to live at the drill site and they would, of necessity, have to live in Craig and commute to the work site. Id. at 50. Accordingly, Chapman insisted, there was a sufficient nexus between the injury and his employment to justify compensation. Id. The Court summarily rejected Chapman's argument: "Under the factual circumstances outlined above, we are not persuaded Chapman was in the course and scope of his employment merely while driving to and from the work site under what can only be described as relatively typical (in Wyoming/Colorado) commuting circumstances." (Chapman, 899 P.2d at 50-51.)