premises rule (Wyoming) · Go Syfert
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premises rule in Wyoming

14 Wyoming opinions name it 1 courts 1963–2018 0 in the last five years

The cases below were cited by Wyoming courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Archuleta v. Carbon County School District No. 1green
wyo · 1990 · cited in 7 Wyoming opinions naming this issue, 1990–2018
2 sentences

2018Archuleta, 787 P.2d at 93 . [¶29] In other words, the premises rule, which we adopted in Archuleta, provides that when an employee is injured on the work premises, that fact will not conclusively establish the'required causal link, but it will raise a presumption that the injury is work related.

1999The premises rule, adopted by this Court in Archuleta v. Carbon County School District No. 1, 787 P.2d 91, 93 (Wyo.1990) establishes a rebuttable presumption of causation when an employee, having fixed hours and place of work, suffers an injury on the premises while at work.

57
Rocky Mountain Tank & Steel Co. v. Ragergreen
wyo · 1967 · cited in 4 Wyoming opinions naming this issue, 1986–1992
2 sentences

1992Similarly, in Rocky Mountain Tank & Steel Co. v. Rager, 423 P.2d 645, 647-48 (Wyo.1967), we declined to apply a premises rule but held instead that a night watchman was entitled to benefits because he was on duty (working) at the time of his death.

1986Our decision in Rocky Mountain Tank & Steel Company v. Rager, Wyo., 423 P.2d 645, 647-648 (1967), supports our rejection of the premises rule.

44
Baker v. Wendy's of Montana, Inc.green
wyo · 1984 · cited in 3 Wyoming opinions naming this issue, 1986–1992
2 sentences

1986See also, e.g., Baker v. Wendy’s of Montana, Inc., Wyo., 687 P.2d 885, 891-892 (1984), and Cottonwood Steel Corporation v. Hansen, Wyo., 655 P.2d 1226, 1232 (1982). 1 If we adopted the premises rule in Wyoming, any harm suffered by an employee on the employer’s premises would occur within the course of employment.

1986See also, e.g., Baker v. Wendy's of Montana, Inc., Wyo., 687 P.2d 885, 891-892 (1984), and Cottonwood *61 Steel Corporation v. Hansen, Wyo., 655 P.2d 1226, 1232 (1982). [1] If we adopted the premises rule in Wyoming, any harm suffered by an employee on the employer's premises would occur within the course of employment.

23
Cottonwood Steel Corp. v. Hansengreen
wyo · 1982 · cited in 3 Wyoming opinions naming this issue, 1986–1992
2 sentences

1986See also, e.g., Baker v. Wendy’s of Montana, Inc., Wyo., 687 P.2d 885, 891-892 (1984), and Cottonwood Steel Corporation v. Hansen, Wyo., 655 P.2d 1226, 1232 (1982). 1 If we adopted the premises rule in Wyoming, any harm suffered by an employee on the employer’s premises would occur within the course of employment.

1986See also, e.g., Baker v. Wendy's of Montana, Inc., Wyo., 687 P.2d 885, 891-892 (1984), and Cottonwood *61 Steel Corporation v. Hansen, Wyo., 655 P.2d 1226, 1232 (1982). [1] If we adopted the premises rule in Wyoming, any harm suffered by an employee on the employer's premises would occur within the course of employment.

23
Saunders v. Industrial Commissiongreen
illappct · 1998 · cited in 2 Wyoming opinions naming this issue, 2006–2006
2 sentences

2006See also, Saunders v. Industrial Comm'n, 301 Ill.App.3d 643 , 235 Ill.Dec. 490 , 705 N.E.2d 103 (1998) (denial of benefits to worker injured while riding double on a forklift in violation of employer's clear directive); Scheller v. Industrial Comm'n, 134 Ariz. 418 , 656 P.2d 1279 (Ct.App.1982) (denying benefits to security worker who pursued criminals off the employer's premises in violation of employer's prohibition against leaving the premises).

2006See also, Saunders v. Industrial Comm'n, 301 Ill.App.3d 643 , 235 Ill.Dec. 490 , 705 N.E.2d 103 (1998) (denial of benefits to worker injured while riding double on a forklift in violation of employer's clear directive); Scheller v. Industrial Comm'n, 134 Ariz. 418 , 656 P.2d 1279 (Ct.App.1982) (denying benefits to security worker who pursued criminals off the employer's premises in violation of employer's prohibition against leaving the premises).

22
H. K. Ferguson Co. v. Willeygreen
wyo · 1977 · cited in 2 Wyoming opinions naming this issue, 1986–1986
2 sentences

1986Unlike the state courts discussed above, we have consistently refused to create a two-part analysis for the phrase “arising out of and in the course of employment.” Instead, we have construed “arising out of” employment to mean the same thing as “in the course of employment.” In Matter of Willey, Wyo., 571 P.2d 248, 250 (1977), we stated: “Although the language contained in § 27-311(n), [W.S.1957, Cum.Supp.1975] is somewhat different from that contained in its predecessor, the meaning has remained the same.

1986Unlike the state courts discussed above, we have consistently refused to create a two-part analysis for the phrase "arising out of and in the course of employment." Instead, we have construed "arising out of" employment to mean the same thing as "in the course of employment." In Matter of Willey, Wyo., 571 P.2d 248, 250 (1977), we stated: "Although the language contained in § 27-311(n), [W.S. 1957, Cum.Supp. 1975] is somewhat different from that contained in its predecessor, the meaning has remained the same.

22

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Wyoming. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Matter of Injury to Corean green
wyo · 1986
2 sentences

1997In Archuleta , we defined the premises rule and discussed its application to periods immediately before and after work: “As to employees having fixed hours and place of work, injuries occurring on the premises while they are going to and from work before or after working hours or at lunchtime are compensable, * * 1 A. Larson, The Law of Workmen’s Compensation § 15.00 at p. 4-3 (1989). * * * ****** We noted in Corean [Matter of Injury to Corean, 723 P.2d 58 (Wyo.1986) ] that on-premises accidents are, indeed, most often causally connected to employment, thereby suggesting that a presumption cre

1997In Archuleta , we defined the premises rule and discussed its application to periods immediately before and after work: "As to employees having fixed hours and place of work, injuries occurring on the premises while they are going to and from work before or after working hours or at lunchtime are compensable, * * *." 1 A. Larson, The Law of Workmen's Compensation § 15.00 at p. 4-3 (1989). * * * * * * * * * We noted in Corean [ Matter of Injury to Corean, 723 P.2d 58 (Wyo.1986)] that on-premises accidents are, indeed, most often causally connected to employment, thereby suggesting that a presum

41990–1997
Scheller v. Industrial Com'n of Arizona green
arizctapp · 1982
2 sentences

2006See also, Saunders v. Industrial Comm'n, 301 Ill.App.3d 643 , 235 Ill.Dec. 490 , 705 N.E.2d 103 (1998) (denial of benefits to worker injured while riding double on a forklift in violation of employer's clear directive); Scheller v. Industrial Comm'n, 134 Ariz. 418 , 656 P.2d 1279 (Ct.App.1982) (denying benefits to security worker who pursued criminals off the employer's premises in violation of employer's prohibition against leaving the premises).

2006See also, Saunders v. Industrial Comm'n, 301 Ill.App.3d 643 , 235 Ill.Dec. 490 , 705 N.E.2d 103 (1998) (denial of benefits to worker injured while riding double on a forklift in violation of employer's clear directive); Scheller v. Industrial Comm'n, 134 Ariz. 418 , 656 P.2d 1279 (Ct.App.1982) (denying benefits to security worker who pursued criminals off the employer's premises in violation of employer's prohibition against leaving the premises).

22006–2006
In the Matter of Carey v. Schroeder Mining Company neutral
wyo · 1955
2 sentences

1997Claim of Carey, 74 Wyo. 37 , 283 P.2d 1005 (1955). * * * * * * Accordingly, we hold that where the elements of the premises rule, as set forth above, have been established, a re-buttable presumption arises that the employee’s injury is causally connected to his employment.

1997Claim of Carey, 74 Wyo. 37 , 283 P.2d 1005 (1955). * * * * * * Accordingly, we hold that where the elements of the premises rule, as set forth above, have been established, a re-buttable presumption arises that the employee’s injury is causally connected to his employment.

21997–1997
Abrams v. Watson green
· 1877
1 sentence

1963The reason for the rule is that since the action is a summary proceeding designed especially for the purpose of a speedy means of recovering possession of real property, tenants withholding the premises in violation of the covenants of their lease cannot through means of a cross-complaint or counterclaim frustrate the extraordinary remedy provided by the statute. * * * ” And Illinois held, in Case v. Rewerts, supra, 145 N.E.2d 256 , where forcible entry and detainer action was brought for the distinctive purpose of obtaining possession of a farm, “no matter not germane to such purpose could be

11963–1963
Collins v. Karatopsky green
· 1880
1 sentence

1963The reason for the rule is that since the action is a summary proceeding designed especially for the purpose of a speedy means of recovering possession of real property, tenants withholding the premises in violation of the covenants of their lease cannot through means of a cross-complaint or counterclaim frustrate the extraordinary remedy provided by the statute. * * * ” And Illinois held, in Case v. Rewerts, supra, 145 N.E.2d 256 , where forcible entry and detainer action was brought for the distinctive purpose of obtaining possession of a farm, “no matter not germane to such purpose could be

11963–1963

Statutes the citing opinions construe

WY § Wyo. Stat. § 27-14-102 (11) WY § Wyo. Stat. § 16-3-114 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 64 (1851–2026) CA 34 (1868–2025) IL 28 (1903–2022) NJ 28 (1940–2026) TX 25 (1921–2024) MD 19 (1969–2025) FL 17 (1933–2016) WY 14 (1963–2018) MI 14 (1885–2016) KS 11 (1934–2009) AR 10 (1959–2009) WA 9 (1931–2025) UT 8 (1912–2019) AZ 8 (1918–1995) OH 7 (1907–2016) PA 7 (1914–2026) TN 7 (1992–2016) LA 7 (1931–2002) MA 7 (1904–2015) MO 6 (1881–2019) CT 6 (1949–2017) WI 5 (1932–2000) NM 5 (1981–1991) MS 5 (1957–2007) OR 5 (1962–2013) MN 5 (1949–2017) ID 5 (1947–2014) NC 5 (1953–2010) VA 4 (1915–1998) DE 4 (1995–2022) OK 4 (1937–2006) AL 3 (1899–1940) DC 3 (1970–2006) GA 3 (1955–1982) IA 3 (1935–1998) NE 3 (1898–2025) AK 3 (1990–1999) ND 3 (2003–2021) KY 2 (1953–1978) RI 2 (1998–2004) MT 2 (1992–2021) SC 2 (1987–2025) VT 2 (1880–1928) NV 2 (1968–1979)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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