Injury Incurred during Post-Meeting Informal Company Recreation Is Not Subject to Workers' Compensation Coverage despite Employee's View That Participation Was Encouraged and Important to Career. (Recent Court Decisions)

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Appeal of Kraft Foods, Inc., 147 N.H. 572, 794 A.2d 779, 2002 N.H. LEXIS 28 (New Hampshire Supreme Court, April 15, 2002)

The New Hampshire Supreme Court recently issued an opinion that serves as an advisory to employees who feel that company outings are "command performances" and undoubtedly spurs a sigh of relief from employers, who frequently sponsor or support sporting events or other recreational outings that are thought to build team spirit or serve as perquisites of the job but are not closely supervised by the company.

Kraft sponsored a company outing in early 1999 at the Waterville Valley Conference Center. Kraft employee Claire Connors attended several mandatory meetings on Friday, January 15 and during the morning of Saturday, January 16. Beginning Saturday afternoon, the respondent was free to attend several optional seminars, go on a sleigh ride, or enjoy free time with her family. On Saturday evening, the petitioner (Kraft) provided several optional recreational events for its employees. On Sunday, the respondent (Connors) had her choice of "winter entertainments" provided by the petitioner, including sleigh rides, skating, and downhill or cross-country skiing. The respondent was also free to …