Justia South Dakota Supreme Court Opinion Summaries
Articles Posted in Labor & Employment Law
Lloyd v. Byrne Brands
Jeremy Lloyd was the general manager at a CiCi's Pizza in Sioux Falls, South Dakota, which was owned by Dakota Land Pizza, and was temporarily managing two CiCi's Pizzas in Omaha, Nebraska, which were owned by Byrne Brands. While traveling between Omaha and Sioux Falls on a trip that was not assigned as part of Lloyd's employment duties, Lloyd was involved in a rollover accident. Lloyd filed a workers' compensation claim against defendants Dakota Land and Byrne Brands. The Department of Labor granted defendants' motions for summary judgment, determining that no genuine issue of material fact demonstrated that Lloyd's injuries arose out of or in the course of his employment. The circuit court affirmed. On appeal, the Supreme Court affirmed, holding that Lloyd's claim did not satisfy the "arising out of" requirement for a workers' compensation claim because it failed to demonstrate that a causal connection existed between the injury and the employment.
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