personal comfort doctrine in South Carolina

2013Dist., 333 S.C. 43, 47-48 , 508 S.E.2d 21, 23 (1998) (noting the personal comfort doctrine "has consistently been limited to imperative acts such as eating, drinking, smoking, seeking relief from discomfort, preparing to begin or quit work, and resting or sleeping"); McCoy, 218 S.C. at 354-56 , 62 S.E.2d at 773-74 (determining an employee on a smoke break who was injured after turning and accidentally walking into a piece of copper piping held by a co-employee was 1 The South Carolina Uninsured Employer's Fund was involved because at the time of Marrs' injury, Saluda's was subject to the Worke

2013Dist., 333 S.C. 43, 47-48 , 508 S.E.2d 21, 23 (1998) (noting the personal comfort doctrine "has consistently been limited to imperative acts such as eating, drinking, smoking, seeking relief from discomfort, preparing to begin or quit work, and resting or sleeping"); McCoy, 218 S.C. at 354-56 , 62 S.E.2d at 773-74 (determining an employee on a smoke break who was injured after turning and accidentally walking into a piece of copper piping held by a co-employee was 1 The South Carolina Uninsured Employer's Fund was involved because at the time of Marrs' injury, Saluda's was subject to the Worke

2013Dist., 333 S.C. 43, 47-48 , 508 S.E.2d 21, 23 (1998) (noting the personal comfort doctrine "has consistently been limited to imperative acts such as eating, drinking, smoking, seeking relief from discomfort, preparing to begin or quit work, and resting or sleeping"); McCoy, 218 S.C. at 354-56 , 62 S.E.2d at 773-74 (determining an employee on a smoke break who was injured after turning and accidentally walking into a piece of copper piping held by a co-employee was 1 The South Carolina Uninsured Employer's Fund was involved because at the time of Marrs' injury, Saluda's was subject to the Worke

2013Dist., 333 S.C. 43, 47-48 , 508 S.E.2d 21, 23 (1998) (noting the personal comfort doctrine "has consistently been limited to imperative acts such as eating, drinking, smoking, seeking relief from discomfort, preparing to begin or quit work, and resting or sleeping"); McCoy, 218 S.C. at 354-56 , 62 S.E.2d at 773-74 (determining an employee on a smoke break who was injured after turning and accidentally walking into a piece of copper piping held by a co-employee was 1 The South Carolina Uninsured Employer's Fund was involved because at the time of Marrs' injury, Saluda's was subject to the Worke

2013Dist., 333 S.C. 43, 47-48 , 508 S.E.2d 21, 23 (1998) (noting the personal comfort doctrine "has consistently been limited to imperative acts such as eating, drinking, smoking, seeking relief from discomfort, preparing to begin or quit work, and resting or sleeping"); McCoy, 218 S.C. at 354-56 , 62 S.E.2d at 773-74 (determining an employee on a smoke break who was injured after turning and accidentally walking into a piece of copper piping held by a co-employee was 1 The South Carolina Uninsured Employer's Fund was involved because at the time of Marrs' injury, Saluda's was subject to the Worke

2013Dist., 333 S.C. 43, 47-48 , 508 S.E.2d 21, 23 (1998) (noting the personal comfort doctrine "has consistently been limited to imperative acts such as eating, drinking, smoking, seeking relief from discomfort, preparing to begin or quit work, and resting or sleeping"); McCoy, 218 S.C. at 354-56 , 62 S.E.2d at 773-74 (determining an employee on a smoke break who was injured after turning and accidentally walking into a piece of copper piping held by a co-employee was 1 The South Carolina Uninsured Employer's Fund was involved because at the time of Marrs' injury, Saluda's was subject to the Worke

2013Ed.) (2012); see Bentley v. Spartanburg Cnty., 398 S.C. 418, 422 , 730 S.E.2d 296, 298 (2012) (citing Professor Larson's treatise to identify the three categories into which work-related injuries fall); Cauley v. Ross Accordingly, we hold the trial court did not err in finding Appellants' actions fell within the personal comfort doctrine.

2013Ed.) (2012); see Bentley v. Spartanburg Cnty., 398 S.C. 418, 422 , 730 S.E.2d 296, 298 (2012) (citing Professor Larson's treatise to identify the three categories into which work-related injuries fall); Cauley v. Ross Accordingly, we hold the trial court did not err in finding Appellants' actions fell within the personal comfort doctrine.

2013Dist., 333 S.C. 43, 47-48 , 508 S.E.2d 21, 23 (1998) (noting the personal comfort doctrine "has consistently been limited to imperative acts such as eating, drinking, smoking, seeking relief from discomfort, preparing to begin or quit work, and resting or sleeping"); McCoy, 218 S.C. at 354-56 , 62 S.E.2d at 773-74 (determining an employee on a smoke break who was injured after turning and accidentally walking into a piece of copper piping held by a co-employee was 1 The South Carolina Uninsured Employer's Fund was involved because at the time of Marrs' injury, Saluda's was subject to the Worke

2013Dist., 333 S.C. 43, 47-48 , 508 S.E.2d 21, 23 (1998) (noting the personal comfort doctrine "has consistently been limited to imperative acts such as eating, drinking, smoking, seeking relief from discomfort, preparing to begin or quit work, and resting or sleeping"); McCoy, 218 S.C. at 354-56 , 62 S.E.2d at 773-74 (determining an employee on a smoke break who was injured after turning and accidentally walking into a piece of copper piping held by a co-employee was 1 The South Carolina Uninsured Employer's Fund was involved because at the time of Marrs' injury, Saluda's was subject to the Worke

2008The personal comfort doctrine states, “Such acts as are necessary to the life, comfort, and convenience of the [employee] while at work, though strictly personal ... and not acts of service, are incidental to the service, and injury sustained in the performance thereof is deemed to have arisen out of the employment.” Id. at 519 , 526 S.E.2d at 730 (citing Osteen, 333 S.C. at 46 , 508 S.E.2d at 23 ).

2008The personal comfort doctrine states, “Such acts as are necessary to the life, comfort, and convenience of the [employee] while at work, though strictly personal ... and not acts of service, are incidental to the service, and injury sustained in the performance thereof is deemed to have arisen out of the employment.” Id. at 519 , 526 S.E.2d at 730 (citing Osteen, 333 S.C. at 46 , 508 S.E.2d at 23 ).

2008See Portee , 234 S.C. at 54 , 106 S.E.2d at 672 .

2008See Portee , 234 S.C. at 54 , 106 S.E.2d at 672 .

2006Osteen, 333 S.C. at 47-48 , 508 S.E.2d at 23 (observing that under workers’ compensation law, "the personal comfort doctrine has consistently been limited to imperative acts such as eating, drinking, smoking, seeking relief from discomfort, preparing to begin or • quit work, and resting or sleeping”); see also Dukes v. Rural Metro Corp., 356 S.C. 107, 110 , 587 S.E.2d 687, 689 (2003) ("The purpose of the personal comfort doctrine is to allow employees to attend to their biological personal requirements.”).

2006Osteen, 333 S.C. at 47-48 , 508 S.E.2d at 23 (observing that under workers’ compensation law, "the personal comfort doctrine has consistently been limited to imperative acts such as eating, drinking, smoking, seeking relief from discomfort, preparing to begin or • quit work, and resting or sleeping”); see also Dukes v. Rural Metro Corp., 356 S.C. 107, 110 , 587 S.E.2d 687, 689 (2003) ("The purpose of the personal comfort doctrine is to allow employees to attend to their biological personal requirements.”).

1998Additionally, in Howell v. Kash & Karry, 264 S.C. 298, 301 , 214 S.E.2d 821, 822 (1975), we stated that "[a]n act outside an employee's regular duties which is undertaken in good faith to advance the employer's interest, whether or not the employee's own assigned work is thereby furthered, is within the course of employment." The injury in Howell occurred while the employee was chasing two boys who had stolen a customer's purse.

1998Additionally, in Howell v. Kash & Karry, 264 S.C. 298, 301 , 214 S.E.2d 821, 822 (1975), we stated that "[a]n act outside an employee's regular duties which is undertaken in good faith to advance the employer's interest, whether or not the employee's own assigned work is thereby furthered, is within the course of employment." The injury in Howell occurred while the employee was chasing two boys who had stolen a customer's purse.