## Facts

- Blanche Strother worked as a cashier for Morrison Cafeteria and routinely handled customer payments.
- Although not a formal duty, she had twice driven the manager to the bank to deposit the cafeteria’s receipts.
- In the two days before the incident, Strother noticed two men in the cafeteria who were not customers or employees; she saw them again the night of the incident.
- After finishing work, Strother drove directly home and, upon arrival, was assaulted and robbed by one of the men she had previously observed at the cafeteria.
- The industrial claims judge found the assailants followed her from work and attacked her because they believed she was carrying the employer’s money.
- The Industrial Relations Commission reversed, concluding the injury arose out of employment but was not sustained in the course of employment because it occurred off premises and after hours.

## Issues

1. Whether an employee assaulted off the employer’s premises and after leaving work sustains an injury “in the course of employment” when the assault is motivated by a work-related risk tied to handling the employer’s money.
2. Whether the “course of employment” requirement may be satisfied when the injury-producing event occurs outside normal time-and-space limits but the origin and cause of the risk are entirely work-related.

## Decision

- The Florida Supreme Court held Strother’s injuries were compensable under workers’ compensation law.
- The court ruled that injuries are compensable when they have their origin and cause entirely within the course of employment and arise out of employment, even if the assault occurs outside workplace time-and-space limits.
- The court quashed the Industrial Relations Commission’s denial of benefits and reinstated the industrial claims judge’s award.

## Legal Principles

- An injury may be “in the course of employment” even when occurring off premises and after hours if the employment-created risk directly causes the injury.
- When an assault is motivated by the employee’s perceived possession of employer funds due to job duties, the resulting injury can satisfy both “arising out of” and “in the course of” employment.
- Fact findings crediting a work-related motive for an assault support compensability where the harm is the culmination of a risk generated by employment.

## Conclusion

Florida workers’ compensation coverage can extend beyond the workplace and working hours when the employment relationship creates a specific risk that leads directly to an injury, such as an off-premises assault motivated by the employee’s work-related handling of employer money.


Strother v. Morrison Cafeteria, 383 So. 2d 623 (Fla. 1980)