On June 20th, 2021, Molly Sullivan, an airline worker for United Airlines, parked in Garage 2 and entered the third-floor walkway on her way into the terminal. She slipped on some water, twisted her left foot, and fell, striking her right knee and arm as she hit the ground.

Sullivan was transported to a local hospital and later received follow-up care from her primary physician and an orthopedist for injuries to her left foot, right knee, and right arm. She went to physical therapy and was released to full duty on September 20th, 2021.

Later, Sullivan filed a workers’ compensation claim for temporary total disability benefits from the date of her injury through her return to full duty, along with medical benefits for her injuries.


Contested Claim

United agreed that Sullivan was disabled during the time but contested the claim because the walkway wasn’t under its control and wasn’t the only means of entry for her job.

A deputy workers’ compensation commissioner ruled that Sullivan’s injuries weren’t compensable and also found that the area where Sullivan fell wasn’t close enough to United’s terminal entrance to be considered an extension of the airline’s premises.

The state Workers’ Compensation Commission reversed the deputy commissioner’s decision, finding that “under the extended premises doctrine, an employee may suffer a compensable injury even though the accident was on property not owned by the employer because the property was ‘in such proximity and relation to the space leased by the employer as to be in practical effect the employer’s premises.'”

The commission said that Sullivan’s incident was close enough to her employer’s place of business to fall under the extended premises doctrine. This led the commission to remand the case to the deputy commissioner, who ruled in Sullivan’s favor.



United filed an appeal with the Virginia Court of Appeals, arguing that the extended premises doctrine doesn’t apply because Sullivan slipped on a walkway over which it had no control, more than 80 yards from its terminal.

In affirming the commission’s decision in favor of Sullivan, the appeals court pointed out that injuries occurring in places where an employer has some kind of right of passage to and from a building are “generally considered to have taken place on the employer’s premises.” This is true even if the employer doesn’t own or lease the place where the injury occurred.

About the Author


Pete Nemmers

Pete Nemmers serves as NASP’s Director of Training Development, bringing a wealth of expertise to the organization. With a background rooted in safety and training, Pete plays a pivotal role in shaping the training programs offered by NASP. Pete ensures that NASP remains at the forefront of safety education, equipping professionals with the knowledge and skills necessary to navigate and excel in the dynamic field of safety.
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