FindLaw KnowledgeBasePublished: 2012-04-13
Workers who are employed in one state, but reside in another, may have questions about which state would handle their workers’ compensation claim if they were ever injured. A number of people in the Tri-State area may live in Connecticut and work in New York or New Jersey and may be unsure which state has jurisdiction of their workers’ compensation claim. They may instinctively file for benefits in the state where they reside.
Such was the case in Baron v. Genlyte Thomas Group, LLC, et al.where a salesman for a New Jersey based lighting fixtures company lived in Connecticut. His territory consisted of three New York counties, and he attended weekly sales meetings in New Jersey. He was injured in a car accident in New York while he was driving to one of his sales meetings in New Jersey.
After his death five months later, his estate sought benefits from the State of Connecticut Workers’ Compensation Commission. After the claim was denied, the Connecticut Appellate Court held that it did not hold jurisdiction over the claim because Connecticut had only a "peripheral relationship" to the employment.
Significant Relationship Analysis
Connecticut law requires that workers’ compensation claimants have a “significant relationship” with employers in the state. This may include relationships with employers based in the state or a substantial amount of work conducted in Connecticut, even though an employer may be based in a different state.
The Baron estate claimed that the salesman had a home office in the state, and this was enough to show a significant relationship between Connecticut and his employer. However, the court reasoned that having a home office merely for convenience was insufficient in establishing the required relationship.
In addition, the court found that infrequent Connecticut business, such as when a New York customer purchased lighting for a Connecticut store also fell short in establishing a significant relationship. It specifically noted that the salesman was not supposed to work with clients in Connecticut because it was a coworker's territory, and that the employer was not aware that he assisted customers in the state.
While this is one interpretation of the relationship requirement, other situations may be viewed differently. If you have been injured and have questions about whether you qualify for benefits, contact an experienced workers’ compensation attorney.