Whether an injury is compensable under the Worker’s Disability Compensation Act (WDCA) (MCL 418.101 et seq); MCL 418.301(1); Whether the injury was work-related; Rakestraw v General Dyamics Land Sys, Inc; Smith v Chrysler Group, LLC; Camburn v Northwest Sch Dist (After Remand); Ream v L E Myers Co; Scope of Michigan Compensation Appellate Commission (MCAC) review; MCL 418.861a; Mudel v Great Atl & Pac Tea Co

Holding that the magistrate erred by finding plaintiff’s death arose out of and in the course of his employment with defendant-LexaMar, and thus was compensable under the WDCA, the court reversed. Plaintiff was killed in a car accident while traveling from work to school. The magistrate found he was entitled to workers’ compensation, finding his travel was supported by and benefitted defendant, which reimbursed a portion of his tuition. On appeal, the court rejected defendant’s argument that, in reviewing the decision of the magistrate, the MCAC failed to conduct a qualitative or quantitative analysis of the record, “failed to make specific findings, and failed to reference the statutory framework that it applied.” It found that “the MCAC’s review was sufficient to discharge its statutory obligation.” However, it agreed with defendant that the MCAC erred as a matter of law by finding plaintiff’s death occurred within the course of his employment. There were no facts presented to support the magistrate’s finding that the college classroom was a “job location” where plaintiff was expected to perform job duties on LexaMar’s behalf. Further, the magistrate’s finding that defendant strongly encouraged plaintiff to take the class was a legal conclusion that expanded existing case law. Neither Smith, Camburn, "nor Ream support the legal conclusion that an employer’s offer of the fringe benefit of free education, no matter how tempting, is the equivalent of compelling the employee to participate in the offered education as part of the employee’s job duties.” Rather, the facts here were “more closely analogous to the facts in Camburn, in which our Supreme Court held that the employee’s injuries were non-compensable. As in Camburn, the employer in this case arguably received a benefit when [plaintiff] gained classroom knowledge that could be used at work and also by trying the method of having employees travel to the college for instruction. However, the fact that an employer someday may benefit from an employee’s training is insufficient to trigger worker’s compensation coverage and does not rise to the level of a ‘special mission’ for the employer, or to the employer deriving a ‘special benefit’ at the time of the employee’s injury.” Thus, the magistrate erred by finding there was a “sufficient nexus” between plaintiff’s employment and his death “to support the legal conclusion that his death arose in the course of his employment.”