Nursing Student’s Fall on Medical Center Employer’s Stairs After Shift But During Student Clinicals Not Compensable

An employee, a patient-care attendant, brought an action against her employer, Medical Center Enterprise (MCE), a medical center seeking workers' compensation benefits for an alleged injury sustained in the course of employment. MCE's motion for summary judgment was granted, and the employee appealed.
The claimant worked at MCE and attended Enterprise Community College to earn her registered-nurse (“RN”)degree. She later was admitted into the nursing program at Wallace Community College (“Wallace”). As part of Wallace's program, the claimant was to attend classes and participate in “clinicals” in which she and other nursing students worked, under the supervision of a Wallace instructor, in the hospital from 7:00 a.m. until 12:00 p.m. Wallace allowed its students to select from three area hospitals in which to perform their clinicals and the claimant chose MCE because it was convenient for her to perform clinicals at the same place at which she was employed. It is undisputed that MCE had not provided benefits to pay for the claimant's schooling to become an RN and that the clinicals were not connected to the claimant's employment at MCE.
On March 12, 2010, the claimant worked the night shift at MCE from 7:00 p.m. on March 11, 2010, until 7:00 a.m. on March 12, 2010. The claimant testified that shortly before 7:00 a.m. on the morning of March 12, 2010, she changed from the “scrubs” she was required to wear for her job with MCE into the nursing “whites” that Wallace requires its nursing students to wear while performing clinicals in a hospital. According to the claimant, after she changed into her whites, she clocked out at 7:01 a.m. and said goodbye to a supervisor. The claimant acknowledged that, at that point, she had no further job duties to perform as a PCA for MCE.
After the claimant clocked out, she proceeded to the MCE lobby to meet her clinical supervisor and the other nursing students taking part in clinicals that day. The claimant agreed that the supervisor and several other Wallace students were present in the MCE lobby and were waiting to start clinicals when she arrived. The claimant stated that, as she reached the lobby, she realized that she had left a folder that contained materials she needed for clinicals in her vehicle. The claimant testified that “I did speak to Dr. Kelley [ (the clinicals supervisor) ] and [told] her I forgot my folder in my car, and she told me to go get it.”After the claimant left the lobby to go to her vehicle, she fell on some stairs in the hallway leading to the parking lot where her vehicle was located. The claimant broke her arm in that fall.
The Court of Civil Appeals affirmed the lower court’s holding that the employee’s injury was not related to her work for the employer, but rather the employee was pursuing her education at the time of the injury, and thus the injury was not compensable. The court reasoned the employee chose to perform those shifts at the medical center due to convenience, the employee had clocked out and said goodbye to a supervisor when she realized she had forgotten a folder for her clinical shift in her car and subsequently fell on some stairs when she left to go to her vehicle, and the employer did not contribute toward the employee's education, did not direct the manner in which she obtained that education, and did not benefit by her participating in the clinical shifts in order to further her education.
The court stated, “In order for an injury which occurs on the employer's premises after the employee finishes work for the day to be compensable, the employee must have been engaged in an act naturally related and incidental to the service or work which he or she was engaged to perform.”
See: McDuffie v. Medical Center Enterprise, 2012 WL 4040369 (Ala.Civ.App. Sep 14, 2012) (not designated for publication).