The claimant was in course of employment when she was injured from a fall while walking between a parking spot leased by her employer and employer’s building as the area was part of the employer’s premises.

In this case, the claimant slipped and fell on her walk into work from an employer-paid parking space while trying to avoid ice. The spot was in a public parking lot, located behind the employer’s building. The spot was leased by the employer, and the claimant was not required to use it. The injury occurred while the claimant walked through a “parklet” owned by the Borough, which was the most direct route to the main entrance of the employer’s building. The spot was assigned to the claimant by the employer and, although the Borough owned the area where the claimant fell, the employer rented the parking space. 

The claimant filed a claim petition, which the employer contested on the basis that the area where the claimant fell, which was a sidewalk adjacent to the employer’s building, was not part of the employer’s premises. The Workers’ Compensation Judge granted the claim petition, finding that the claimant parked in a space assigned to her by the employer and walked the most direct route to the employer’s business. Although the Borough owned the area where the claimant fell, the judge found the employer rented the parking space. Because he found the space was part of the employer’s premises and the claimant was walking from her space to the work site, the judge concluded that the claimant was injured in the course of her employment. The employer appealed to the Workers’ Compensation Appeal Board, which affirmed. 

The employer then appealed to the Commonwealth Court, arguing that the matter was controlled by legal precedent excluding private parking lots from an employer’s premises. The employer argued that because the claimant was not required to use the parking space, the term “premises” in § 301(c) of the Act did not include her parking space or her route to the work site.

The court rejected this argument and dismissed the employer’s appeal. The court held that the claimant established course of employment by showing that she was undertaking a reasonable means of ingress at the time of her injury. According to the court, the reasonable means of access that the claimant used between her assigned parking space and the employer’s main entrance is properly construed as being part of the employer’s premises, rendering her injury compensable under the Act. 
 

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