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injuries are not so easily determined. For example, one court granted
benefits to a school janitor who injured her knee while reaching down to
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pick up a pill she dropped on the floor. However, another court denied
benefits to a nurse who twisted and injured her knee after standing up
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and turning in a patient’s room. The current standard applied by the
courts is that the injury is compensable so long as the injury was caused
by an activity the employee engaged in as part of his or her job, or the
injury was the result of some special danger of the employment.
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An employee’s injury must also occur in the course of his
employment. “In the course of employment” generally means that the
injury occurred within the time period of the employment, at a place
where the employee may be in the performance of his duties, and while
the employee is fulfilling those duties. For example, an employee who
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is injured while going to or coming from work is not covered under
workers’ compensation (subject to some exceptions). An employee
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who makes a deviation and detour from his employment would also not
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be covered. For example, if a pizza delivery man decides after
delivering his pizza to run across town to the mall to purchase a new pair
of shoes, his employer will probably not be required to pay benefits if the
pizza delivery man has a car accident on his way to the mall. However,
under the “egress/ingress” rule, the courts have granted benefits to
8 See Harris v. Peach County Bd. Of Comm’rs., 296 Ga. App. 225 (2009).
9 See St. Joseph Hosp. v. Ward, 300 Ga. App. 845 (2009), overruled in part by
Cartersville City Schs. v. Johnson, 345 Ga. App. 290 (2018).
Id.
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11 See Thornton v. Hartford Acc. & Indem. Co., 198 Ga. 786 (1945).
12 See Wilcox v. Shepherd Lumber Corp., 80 Ga. App. 71 (1949).
13 See Travelers Ins. Co. v. Curry, 76 Ga. App. 312 (1947).
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