Mary E. Spellman, Employee Below v. Christiana Care Health Services, Employer Below

Summary

The Court affirmed the Superior Court's judgment denying Spellman's workers' compensation claim, but rested its decision on a different analytical ground. It held that the going-and-coming rule and its exceptions are secondary analytical tools, and that the scope-of-employment inquiry should begin with the employment agreement and the totality of the circumstances. Under Spellman's employment terms, she was off the clock, was not being reimbursed for the travel, and was traveling for personal purposes, so her injury did not arise out of or occur in the course of employment.