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Lapsley v. Twp. of Sparta

New Jersey Appellate Division

January 29, 2021

In Lapsley v. Twp. of Sparta, the Appellate Division reviewed an award of the Division of Workers’ Compensation for injuries suffered by a public librarian when she was struck by a snowplow while leaving work. The Workers’ Compensation judge held that the injury occurred on the employer’s premises because the librarian was in a parking lot serving multiple municipal services – including the library – when the injury occurred. But the Appellate Division disagreed and held that “A mechanical application of the premise rule” was inappropriate. The librarian was not on the library’s premises. The library did not instruct employees where to park or how to come-and-go from work. The sole fact that the lot was a municipal lot did not bring the injury within the purview of the Workers’ Compensation Act.

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