Supreme Court of New Hampshire

Appeal of Elba Hawes

June 3, 2022

Summary

The Supreme Court of New Hampshire reversed the Compensation Appeals Board and held that Elba Hawes’ injuries are compensable under the special‑errand exception to the “coming and going” rule, finding both that the injury occurred in the course of employment and that it arose out of an employment‑created risk. The court also concluded that the first element of the Murphy test is satisfied as a matter of law.