Commission Ruled Teacher’s Injuries Sustained While Skating With Students Were Compensable

A majority of the Illinois Industrial Commission awarded benefits to claimant-teacher, who was injured while participating in a roller skating program with students, where evidence indicated the class was part of a structured teacher/student activity and claimant’s participation was a benefit for students and defendant. (Mary Hatfield v. Washington School District No. 50, (Ill.Ind.Com.), Nos.96WC10253, 00IIC 0896, Jan 3, 2001.)

Claimant, a teacher of computer and gifted classes, was injured while attending a roller skating program for students. The program was offered to the students during normal school hours as part of their physical education class and was designed ti improve their self-esteem, to increase the curriculum, to educate the students in a lifelong activity and to teach safety rules. Claimant testified she was encouraged by the principal to attend the roller skating program. She understood her duties to be that of supervisor, to foster morale, to aid in the learning environment and to enhance the relationship of the teachers and students. She further testified that at the time of injury, the principal was present and observed claimant preparing to skate and, in fact, was preparing to skate. The principal testified that the teachers’ participation was appreciated to assist in supervision of the students.

The arbitrator awarded benefits, finding claimant was in the performance of her duties at the time of the accident and injury arose out of and in the course of her employment. The arbitrator noted the skating program was organized, sanctioned and sponsored by the school. The arbitrator further noted participating teachers were allowed to forego their otherwise normal classroom duties to attend the skating event and encouraged to attend the event. Also, the school made available to the teachers their skates, defendant knew teachers would participate and defendant wanted and encouraged their participation. In addition, the arbitrator found significant the principal’s testimony that the skating class was a part of a structured teacher/student activity. The arbitrator determined claimant’s participation was for the benefit of the students and a benefit therefore to defendant.

Upon review, a majority of the Commission affirmed and adopted the decision of the arbitrator.

The dissent argued the accident was excluded by section 11 of the Workers’ Compensation Act, noting claimant admitted her participation in roller skating was voluntary and recreational and her principal testified roller skating was not part of her school assignment.