## Facts

- Christie R. Coleman worked for Armour Swift-Eckrich and was required to attend a workplace meeting.
- While waiting for the meeting to begin, Coleman sat in a rolling chair with her feet propped on another chair.
- A coworker approached from behind, grabbed the back of Coleman’s chair, and dumped her onto the floor.
- Coleman suffered a back injury from the fall.
- Coleman did not provoke, encourage, or participate in horseplay, and there was no evidence the employer condoned such conduct or that similar horseplay was common.

## Issues

1. Whether an injury to a nonparticipating employee, caused by a coworker’s workplace horseplay while the employee is engaged in a work-related activity, arises out of and in the course of employment under the Kansas Workers Compensation Act.
2. Whether prior Kansas precedent requiring proof of the coworker’s habitual horseplay and employer knowledge controls compensability in nonparticipant horseplay cases.

## Decision

- The Kansas Supreme Court reversed the denial of workers’ compensation benefits and remanded with directions.
- The court held Coleman’s injury arose out of and in the course of employment and was compensable.
- The court rejected applying a restrictive horseplay test to nonparticipating employees that required proof of the actor’s habitual misconduct and employer notice.
- The court adopted the rule that injury to a nonparticipating employee from workplace horseplay arises out of employment.

## Legal Principles

- Injuries to nonparticipating employees caused by workplace horseplay arise out of employment and are compensable under the Kansas Workers Compensation Act.
- “Arising out of” employment focuses on work connection and risk: whether employment placed the employee in the setting and circumstances where the injury occurred.
- In horseplay cases, a key distinction is between employees who participate in the horseplay and employees injured while performing ordinary work or work-incidental activity without participating.
- The remedial purpose of the Kansas Workers Compensation Act supports a broad construction favoring coverage for work-connected injuries.

## Conclusion

Because Coleman was a nonparticipating employee injured during working time while present for a required meeting, the risk of coworker horseplay was a work-connected risk, making her injury compensable under the Kansas Workers Compensation Act.


Coleman v. Armour Swift-Eckrich, 281 Kan. 381, 130 P.3d 111 (2006)