special errand exception in North Carolina

7 North Carolina opinions name it 2 courts 1995–2011 0 in the last five years

The cases below were cited by North Carolina 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 (1)

Case	Followed	Cited
Deese v. Champion International Corp.green nc · 2000 · cited in 1 North Carolina opinions naming this issue, 2003–2003 2 sentences 2003See Deese v. Champion Int’l Corp., 352 N.C. 109, 116 , 726 530 S.E.2d 549, 553 (2000) (the Commission is the “sole judge of the weight and credibility of the evidence”). 2003See Deese v. Champion Int’l Corp., 352 N.C. 109, 116 , 726 530 S.E.2d 549, 553 (2000) (the Commission is the “sole judge of the weight and credibility of the evidence”).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in North Carolina. Read the followed side critically anyway.

Also cited on this issue (10)

Case	Cited	Years
Royster v. Culp, Inc. green nc · 1996 2 sentences 2011The North Carolina Supreme Court further Page 7 articulated the special errand exception, writing that the "coming and going rule" does not apply "if the employee at the time of the accident is acting in the course of his employment and in the performance of his employment and in the performance of some duty, errand, or mission thereto." Royster v. Culp , 343 N.C. 279 , 283 (1996). 2011The North Carolina Supreme Court further Page 7 articulated the special errand exception, writing that the "coming and going rule" does not apply "if the employee at the time of the accident is acting in the course of his employment and in the performance of his employment and in the performance of some duty, errand, or mission thereto." Royster v. Culp , 343 N.C. 279 , 283 (1996).	1	2011–2011
Schmoyer v. Church of Jesus Christ of Latter Day Saints green ncctapp · 1986 1 sentence 2011Schmoyer v. Church of Jesus Christ of Latter Day Saints , 81 N.C.	1	2011–2011
Pollock v. Reeves Bros., Inc. green nc · 1985 2 sentences 2011Regarding the special errand exception, the North Carolina Supreme Court has held "when a superior directs a subordinate employee to go on an errand or perform some duty beyond his normal duties, an injury sustained in the course of that task is compensable." Pollock v. Reeves Bros., Inc . 313 N.C. 287 , 294 (1985). 2011Regarding the special errand exception, the North Carolina Supreme Court has held "when a superior directs a subordinate employee to go on an errand or perform some duty beyond his normal duties, an injury sustained in the course of that task is compensable." Pollock v. Reeves Bros., Inc . 313 N.C. 287 , 294 (1985).	1	2011–2011
Massey v. . Board of Education green nc · 1933 2 sentences 2005Massey v. Board of Education, 204 N.C. 193 , 167 S.E. 695 (1933). . . . . 4. . . . [P]laintiff's accident does not fall under the special errand exception to the coming and going rule. 2005Massey v. Board of Education, 204 N.C. 193 , 167 S.E. 695 (1933). . . . . 4. . . . [P]laintiff's accident does not fall under the special errand exception to the coming and going rule.	1	2005–2005
Powers v. Lady's Funeral Home green nc · 1982 2 sentences 2003Powers, 306 N.C. 728 , 295 S.E.2d 473 (finding employee to be on a special errand where employee was performing duties incident to performance of late-night, emergency embalming for employer’s business); Felton v. Hospital Guild, 57 N.C. 2003Powers, 306 N.C. 728 , 295 S.E.2d 473 (finding employee to be on a special errand where employee was performing duties incident to performance of late-night, emergency embalming for employer’s business); Felton v. Hospital Guild, 57 N.C.	1	2003–2003
Guest v. Brenner Iron & Metal Company green nc · 1955 2 sentences 2003Guest v. Iron Metal Co ., 241 N.C. 448 , 452 , 85 S.E.2d 596 , 600 (1955); Deseth v. Lenscrafters, Inc ., ___ N.C. 2003Guest v. Iron Metal Co ., 241 N.C. 448 , 452 , 85 S.E.2d 596 , 600 (1955); Deseth v. Lenscrafters, Inc ., ___ N.C.	1	2003–2003
Felton v. Hospital Guild of Thomasville, Inc. green ncctapp · 1982 1 sentence 2003Powers, 306 N.C. 728 , 295 S.E.2d 473 (finding employee to be on a special errand where employee was performing duties incident to performance of late-night, emergency embalming for employer’s business); Felton v. Hospital Guild, 57 N.C.	1	2003–2003
Aaron v. New Fortis Homes, Inc. green ncctapp · 1997 1 sentence 2001Aaron v. New Fortis Homes, Inc ., 127 N.C.	1	2001–2001
McBride v. Peony Corp. green ncctapp · 1987 1 sentence 1995This argument has been specifically rejected by this Court, McBride v. Peony Corp., 84 N.C.	1	1995–1995
Jones v. Planters National Bank & Trust Co. neutral nc · 1934 2 sentences 1995Our Supreme Court applied the special errand exception in the case of Jones v. Trust Co., 206 N.C. 214 , 173 S.E. 595 (1934). 1995Our Supreme Court applied the special errand exception in the case of Jones v. Trust Co., 206 N.C. 214 , 173 S.E. 595 (1934).	1	1995–1995

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 97-2 (3)

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

CA 23 (1940–2024) FL 11 (1981–2012) UT 8 (1984–2014) NM 8 (1960–2014) NC 7 (1995–2011) NY 6 (1986–2023) OR 5 (1987–2000) TN 4 (2004–2016) VA 4 (1996–2001) WV 4 (1974–2002) NE 3 (1990–2019) ID 3 (2015–2019) IA 3 (1996–2015) MN 3 (1963–2026) MD 3 (1980–1996) AK 3 (1979–1991) NJ 3 (1974–1977) AL 2 (1987–2010) DE 2 (1993–2018) SC 2 (2009–2015) ME 2 (1978–2006) MO 2 (1995–1998)

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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