## Facts

- Robert Jumpp, Jr. worked for the City of Ventnor as a pumping-station operator, monitoring and inspecting municipal water and sewer facilities.
- The job required travel among multiple dispersed sites; Jumpp used a city-owned vehicle to move between locations during the workday.
- His routine began at the public works office, then he conducted rounds and inspected all sites twice daily, leaving him without fixed meal or break times.
- With his supervisor’s knowledge and permission, Jumpp made brief stops for food, beverages, restroom use, and routinely stopped at a post office on his route to retrieve personal mail.
- On May 5, 1998, while en route to a scheduled inspection, Jumpp parked near the post office, left the city vehicle running, entered to check his personal mail, and slipped and fell while returning to the vehicle.
- He suffered serious injuries (including a fractured pelvis) and sought workers’ compensation benefits; the City denied compensability.

## Issues

1. Whether a traveling, off-premises employee injured during the workday while completing a personal errand is “engaged in the direct performance of duties assigned or directed by the employer” under N.J.S.A. 34:15-36.
2. Whether the “minor deviation” doctrine can render compensable an off-premises injury occurring during an employer-permitted stop to retrieve personal mail.

## Decision

- The Supreme Court of New Jersey affirmed the denial of workers’ compensation benefits.
- Jumpp’s injuries were not compensable because, at the time of injury, he was on a purely personal errand and not engaged in the direct performance of assigned or directed duties.
- The Court recognized that minor deviations may remain compensable after the 1979 amendments, but held this deviation fell outside that limited category.
- Supervisory knowledge or permission for the stop did not convert the errand into an assigned or directed duty.

## Legal Principles

- For off-premises employees, N.J.S.A. 34:15-36 deems an employee in the course of employment only when the employee is “engaged in the direct performance of duties assigned or directed by the employer.”
- The 1979–80 statutory amendments narrowed coverage for off-premises accidents and require a task-specific connection between the activity at the time of injury and assigned work duties.
- Minor deviations and personal comfort activities may remain compensable, but a deviation undertaken solely for a personal errand is not within the statute’s “direct performance” requirement.
- Being on paid time, traveling in an employer vehicle, and acting with supervisory acquiescence does not, without more, satisfy the statutory standard for off-premises coverage.

## Conclusion

A mobile employee injured off-premises during a brief, supervisor-permitted stop to retrieve personal mail was not entitled to workers’ compensation because the injury occurred during a personal errand rather than the direct performance of assigned or directed job duties.


Jumpp v. City of Ventnor, 828 A.2d 905 (N.J. 2003)