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 · Updated October 17, 2026

Decision: Cardillo v. Liberty Mutual Ins. Co., 330 U.S. 469 (1947).

Cardillo v. Liberty Mutual Insurance Co. reviewed a death during an employee’s journey home under the District of Columbia compensation statute. Electrician Clarence Ticer worked at Quantico, Virginia. His employer had agreed to furnish transportation and instead paid a daily allowance; the employees arranged a car pool. Ticer suffered a fatal injury while driving home. The Supreme Court decided the case on March 10, 1947. This is a historical D.C. compensation decision, not a statement of California’s current coverage rules.

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 deputy commissioner could reasonably find that the travel allowance carried out the employer’s promise to provide transportation. The Court distinguished that contractual obligation from mere reimbursement of commuting costs. Employer control of the journey was relevant but did not decide the issue. Cardillo, 330 U.S. at 479–485.

The widow’s award was sustained

The Court reversed the court of appeals. Because the deputy commissioner’s inference had support in the evidence and was consistent with the statute, the reviewing court could not replace it with its preferred inference. Cardillo, 330 U.S. at 477–478, 485.

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.