## Facts

- Ralph D. Ewing owned and operated an automobile dealership in Beaver, Pennsylvania, consisting of a garage, showroom, and used-car lot.
- Haywood Taylor worked for Ewing as a “general utility man” for $35 per week. His usual work included cleaning the offices, showroom, and garage, and servicing cars.
- On July 10, 1947, during Taylor’s regular workday, Taylor had no remaining tasks at the garage or showroom.
- Ewing directed Taylor to go to Ewing’s private residence and cut the grass using Ewing’s power lawn mower.
- While Taylor was trying to adjust the mower belt—after Ewing called Taylor’s attention to the belt—Taylor injured the index finger of his right hand, requiring partial amputation.
- Taylor sought workers’ compensation benefits from Ewing and Ewing’s workers’ compensation carrier.
- The compensation authorities made an award to Taylor, and the Court of Common Pleas affirmed and entered judgment for Taylor.
- The insurance carrier appealed to the Pennsylvania Superior Court, arguing Taylor’s injury did not occur in the course of employment and that coverage was limited to the dealership premises and operations described in the workers’ compensation policy.
- The record also showed Ewing had separate residence-related insurance that referenced coverage for domestic and/or agricultural employees, which the carrier used to argue Taylor should be treated as a domestic worker for the lawn-mowing task.

## Issues

1. Did Taylor’s injury occur “in the course of employment” under the Pennsylvania Workmen’s Compensation Act when, during working hours, he was sent by his employer from the dealership to the employer’s home to mow the lawn and was injured while doing that assigned task?
2. Could the workers’ compensation carrier avoid liability by claiming the accident happened at the employer’s residence and involved work outside the dealership operations and locations listed in the policy?

## Decision

- The Pennsylvania Superior Court affirmed the judgment for Taylor and left the compensation award in place.
- The court held Taylor’s injury occurred in the course of his employment because he was performing a task his employer directed him to do during his workday.
- The court rejected the carrier’s attempt to treat the lawn-mowing assignment as outside the employment relationship or outside the workers’ compensation policy merely because it occurred at the employer’s home and was not part of the dealership’s day-to-day business operations.

## Legal Principles

- An employee acts in the course of employment when, during the employment period, the employee performs work the employer directs, even if the work is not the employee’s ordinary task.
- The course of employment is not confined to the employer’s usual business premises when the employee is sent off-site by the employer to perform an assigned job.
- A temporary assignment that benefits the employer and is done under the employer’s direction does not, by itself, convert a business employee into a domestic employee for workers’ compensation purposes.
- Policy descriptions of business operations and listed locations do not defeat workers’ compensation liability where the claimant remains an employee and the injury occurs while carrying out the employer’s work order.

## Conclusion

Because Taylor was Ewing’s utility employee and was injured during working hours while performing a job Ewing specifically directed him to do—mowing the grass at Ewing’s residence—the injury occurred in the course of employment, and the Superior Court affirmed the compensation award and the insurer’s responsibility to pay it.


Taylor v. Ewing, 70 A.2d 456 (1950)