Workers’ Compensation · Primary-source case analysis

Cardillo: Travel Can Fall Within Compensation Coverage When Its Hazards Become Employment Hazards

By Aneeta Mishra and Timothy Chan

Published August 31, 2026

Cardillo v. Liberty Mutual Insurance Co. reviewed injuries during employee travel under the District of Columbia compensation statute.

Ordinary commuting is generally outside coverage

The usual journey between home and a fixed workplace presents public travel risks rather than hazards of the service.

Employment circumstances can create exceptions

Employer-furnished transportation, payment for travel, remote assignments, or practical transportation arrangements may connect the journey to the work.

Administrative factfinding received deference

The statutory presumption and evidentiary record allowed reasonable inferences about the employment relationship and the character of the travel.

The awards were reinstated

The Court rejected an overly narrow appellate approach and sustained the deputy commissioner’s supported course-of-employment determinations.

Key takeaways

• Identify who furnished, controlled, or paid for transportation.
• Document the route, assignment, and employment expectations.
• Distinguish an ordinary commute from a special employment journey.
• Apply the jurisdiction’s current statutory presumptions and exceptions.