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Workers’ Compensation and Offsite Social or Recreational Activities


Teambuilding in the workplace is a strategy for increasing efficiency and improving job satisfaction. Generally, teambuilding activities are designed to help workers maximize skills for future interactions with coworkers and peers by creating opportunities for collaboration in a variety of non-work-related settings.  As indicated by the results of a recent jobs survey on intergenerational workplace approaches by Mavenlink, a cloud-based software company, as reported on recently by Forbes, team building is an important element of creating solid and productive working environment.

Of course, accidents can occur during employee teambuilding activities. Recently, a Florida District Court of Appeals was called upon to decide whether an employee who was injured during a teambuilding activity had a valid workers’ compensation benefit claim.

Florida’s Workers’ Compensation Law – Recreational and Social Activities 

Under a provision of Florida’s state workers’ compensation law that covers recreational and social activities, compensation is not available to injured employees unless these activities:

  • are a required element of the employment, and
  • produce a direct benefit to the employer beyond the improvement in health and morale that is common for general recreational and social activities.

Application: Reynolds v. Anixter Power Solutions

In a case that was decided by the Florida District Court of Appeal last December, the court found that an employee who was injured during a bowling teambuilding activity had a work-related injury for which she could file a workers’ compensation claim.

In this case, Reynolds v. Anixter Power Solutions, the plaintiff/employee hurt her ankle during a teambuilding bowling event. Although the court noted the obvious, which is that bowling can constitute a recreational activity, the court held that in this case, bowling was, in fact, not a recreational activity that would exclude the worker from filing a worker’s compensation claim under Florida law.

In other words, the court found that the bowling activity:

  • was a required element of the plaintiff’s employment, and
  • produced a direct benefit to the employer beyond improvement in employee health and morale.

The court noted a number of factors related to the particular bowling outing at issue in reaching its decision. Some of these factors were:

  • the bowling activity was conducted during regular work hours
  • employees who attended the event were paid
  • one of purposes of the event was to discuss business goals for the coming year

Another factor that the court discussed was that the plaintiff was not told that she would have an option besides attending the bowling activity; she was not advised that she could not bowl and either work as usual or take a vacation day. Also, although the invitation to the bowling event was sent by an email, and the invited employees could accept or decline the email invitation, the court decided that this option alone was not enough to establish that the bowling outing was voluntary.

As the court’s decision in Reynolds v. Anixter Power Solutions illustrates, whether an injury is work-related for purposes of filing a workers’ compensation claim is not always clear. If you are injured and need to know if your claim is work-related, or if you have other questions about a potential workers’ compensation claim, contact Sholtes Law, PLLC to speak with an experienced Fort Pierce personal injury lawyer in serving St. Lucie and Martin County.



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