## Facts

- Charlotte Smallwood worked for about five years at Winn-Dixie’s Russellville, Alabama store.
- Winn-Dixie directed Smallwood to work the first three days of the next week at a different Winn-Dixie store in Moulton, about 30 miles away.
- Winn-Dixie told Smallwood that another employee on temporary assignment should travel with her to and from Moulton for those three days.
- The employees met each morning at the Russellville Winn-Dixie, drove together to Moulton, and returned together to Russellville at the end of the day.
- Smallwood was not paid for travel time, but she had to report and clock in at the Moulton store at her regular start time (7:00 a.m.).
- Smallwood had only once before been assigned to work at another store.
- On the last day of the temporary assignment, while returning from Moulton to Russellville, Smallwood was injured in an automobile accident.
- Smallwood sought workers’ compensation benefits; Winn-Dixie denied compensability under the going-and-coming rule.
- The trial court granted summary judgment for Smallwood, finding the accident arose out of and in the course of employment.

## Issues

1. Whether injuries from an automobile accident during return travel from a temporary, employer-directed assignment at a distant location arose out of and in the course of employment under Alabama workers’ compensation law.
2. Whether the going-and-coming rule barred compensation where the employer directed the travel arrangement but did not pay for travel time.

## Decision

- The Alabama Court of Civil Appeals affirmed summary judgment for the employee.
- The court held the accident arose out of and in the course of Smallwood’s employment.
- The court treated the travel as a required incident of the temporary assignment, not ordinary commuting.
- The court concluded that legal evidence supported the trial court’s determination, and the judgment would not be disturbed on appeal.

## Legal Principles

- A workers’ compensation injury is compensable when caused by an accident arising out of and in the course of employment.
- Under the going-and-coming rule, injuries while traveling to and from work are generally not compensable.
- An exception applies when travel is sufficiently connected to the employment, including when it is undertaken for the employer’s business pursuant to the employer’s requirements or arrangements (such as a temporary assignment to a distant location and employer-directed transportation coordination).
- Lack of travel-time compensation is relevant but not controlling when the employer directs and benefits from the travel.
- In Alabama workers’ compensation appeals, trial-court findings supported by any legal evidence are upheld.

## Conclusion

Because Winn-Dixie sent Smallwood on a temporary assignment to a distant store and directed the shared travel arrangement that enabled the assignment, her return trip was considered within the course of employment, making her accident-related injuries compensable under Alabama workers’ compensation law.


Winn-Dixie Stores, Inc. v. Smallwood, 516 So. 2d 716 (Ala. Civ. App. 1987)