In D. Sekulski v. WCAB (Indy Associates) the Claimant was a maintenance man for apartments. He carried a beeper and was to remain within 15 minutes away in case he needed to respond. While on his way home from a bowling alley, the Claimant was assaulted. The WCJ, Board and Commonwealth Court found him out of the course and scope of employment. The Court distinguished precedents that awarded benefits when the Claimant was on a lunch break, on a special mission for employer or on travelling employee status. The Court concluded that without more, the claimant who is simply "on call" is not furthering the employer's affairs.
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