## Facts

- Albert Beauchesne worked for David London & Co., a family-owned business.
- On December 24, 1974, the company held an annual Christmas party on the third floor of its building after work stopped around 2:30 p.m.
- The employer provided pizza, soda, beer, and whiskey; employees were told they could attend or leave early and would be paid for a full day either way.
- Paychecks and $10 Christmas bonuses were distributed at the party.
- Beauchesne drank alcohol, became intoxicated, and around 4:00 p.m. fell from a third-floor window.
- He suffered severe injuries, including fractures and vascular damage leading to an above-the-knee amputation.
- A workers’ compensation trial commissioner found Beauchesne was intoxicated but that the injury occurred in the employment, connected with and referable to it; the full commission affirmed.
- The employer appealed to the Rhode Island Supreme Court.

## Issues

1. Whether injuries sustained at an employer-sponsored Christmas party on the employer’s premises during paid time were “in the course of” and “arising out of” employment for workers’ compensation purposes.
2. Whether the statutory intoxication bar precluded compensation where the employer furnished and condoned alcohol at the party.

## Decision

- The Supreme Court of Rhode Island affirmed the award of workers’ compensation benefits.
- The court held there was legally sufficient evidence that the party was sufficiently employment-related for the injury to be within the course of and arising out of employment.
- The court held the intoxication defense did not bar recovery on these facts because the employer supplied and permitted alcohol consumption during the employer-organized event.
- On review, the court treated its role as determining whether legal evidence supported the commission’s findings.

## Legal Principles

- Injuries at employer-sponsored social or recreational events may be compensable when the event is closely tied to employment, including factors such as employer premises, timing during work hours, paid time, employer control or sponsorship, and business-related aspects (e.g., distribution of wages or bonuses).
- Workers’ compensation intoxication exclusions are narrowly applied and may not defeat compensation where the employer affirmatively furnishes, encourages, or condones the drinking that contributes to the injury.
- Appellate review of workers’ compensation findings is limited to whether there is legal evidence supporting the commission’s determinations.

## Conclusion

Because the Christmas party was integrated into the workday and employer-sponsored on the premises with paid time and business-related elements, the employee’s injuries were deemed to arise in the course of employment, and the employer could not avoid liability by invoking intoxication after providing and permitting the alcohol that contributed to the risk.


Beauchesne v. David London & Co., 375 A.2d 920 (R.I. 1977)