Johnson v. ABM: Getting Up at Home to Answer a Work Call Caused a Compensable Knee Injury

When you cover work calls from home, the boundary between your job and your personal time may be less obvious than it is at the workplace. If you are injured while responding, the details of the work arrangement and the task you were performing can be important.

In Johnson v. ABM Industries, Inc., No. ADJ17714627 (WCAB Jan. 30, 2025), an engineer injured his knee while getting out of a chair at home to answer a coworker’s call. The Board left the industrial-injury finding in place. His credited testimony about the work call and on-call arrangement, together with the medical evidence, established the employment connection.

The worker recognized the call and got up to respond

Robert Johnson worked as a stationary engineer and described his role as chief engineer. Other engineers contacted him about emergencies and other jobsite matters during off hours.

He testified that, while sitting in a recliner at home, he heard the distinctive ringtone he had assigned to a coworker. His phone was in another room. He stood up quickly to answer, his knee buckled, and he fell with his weight over the knee. He later underwent surgery for a torn ligament.

The employer disputed whether he was working when that happened. The case therefore required more than establishing that the fall occurred at home. The judge examined why Johnson stood up and what his employer expected of him then.

The work arrangement had support beyond a general claim of being available

The collective bargaining agreement quoted in Johnson said an off-hours phone ordinarily did not restrict an engineer’s activities. It separately addressed specifically communicated standby availability and pay, as well as electronic callback work. Johnson also testified about an arrangement with the building manager for logging his on-call hours.

The Johnson report’s account of the pay statement included on-call hours. The employer’s incident report described him as working from home on call when he got up and fell. These documents formed part of the evidence considered alongside his testimony.

The judge focused on the duty being performed. Johnson recognized a coworker’s call about work and moved to answer it. His testimony about the manager’s arrangement was unrebutted, and he described receiving numerous off-hours calls from the engineers he supervised.

Those facts supplied a concrete connection between the movement and the job. They were more informative than using “on call” or “standby” as labels without explaining what either meant in practice.

The judge resolved conflicting accounts through the trial evidence

Some early medical and ambulance records described Johnson as having been asleep and getting up to go to bed. The employer relied on those descriptions to challenge his later account of answering the work call.

At trial, Johnson testified that he was awake and had stood up because the phone rang. He also explained a discrepancy between the clock time he described and the military-time notation in his deposition. The judge accepted that explanation and found his trial testimony credible.

The Johnson panel reviewed the hearing transcript, gave weight to the judge’s opportunity to observe the witnesses, and found no sufficiently strong evidence to reject that credibility finding.

For a worker with conflicting records, the practical lesson is to identify and explain the discrepancy accurately. Preserve the original records. A clear account and corroborating evidence help the judge evaluate which version the record supports.

The medical evidence explained how the movement injured the knee

QME Juon-Kin Fong, M.D., described a significant ligament injury when Johnson stood, the knee gave way and his weight fell over it. His initial report quoted in Johnson addressed the mechanism, surgery and examination findings. After later reviewing medical records and the deposition transcript, he maintained his opinions.

The doctor also identified Johnson’s physical condition as increasing the pressure involved. The judge considered that medical explanation while asking whether the work-related movement contributed to the injury.

The employer argued that standing up was a normal movement that could have happened anywhere. The adopted report applied the requirement that employment contribute causally to the injury. The reason Johnson stood up—to answer the recognized work call—connected the movement to his duties, and the medical evidence explained the resulting injury.

The Johnson report applied authorities including South Coast Framing, Inc. v. Workers’ Compensation Appeals Board, 61 Cal.4th 291 (2015), concerning industrial contribution and aggravation. The employment connection and the injury mechanism worked together in the analysis.

The Board preserved the injury finding; other benefit issues remained deferred

The judge found the injury to Johnson’s right knee, leg and lower leg industrially compensable and deferred the other issues with jurisdiction reserved. The Board adopted the report and denied the employer’s petition in Johnson.

The ruling established the work connection on the evidence presented. The particular amounts and other benefit questions were left for the remaining proceedings.

Document the task, the arrangement and the injury

If an injury occurs while responding to work from home, preserve the on-call schedule, relevant agreement or policy, pay records, employer messages and incident report. Keep call records or messages that are available. Identify who was contacting you and the work task involved.

Give the medical evaluator an accurate account of the movement and a complete medical history. Ask for any differences between early records and later recollection to be addressed openly.

Johnson shows how those details can make an off-premises claim understandable: An actual work arrangement, a recognized work call, a movement to respond, and medical evidence explaining the injury.

Our Avolevan analysis addresses a different ordinary-movement dispute involving cumulative knee aggravation. For an injury while responding to work at home, see our California workers’ compensation practice.