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02/22/21 National Workers Compensation Defense Network (NWCDN) In 1979 the New Jersey legislature adopted a change to N.J.S.A. 34:15-7 to add that recreational and social activities are not compensable unless the injured worker could prove that the activity promoted a benefit to the employer beyond improvement of health and morale. Prior Supreme Court cases have already made clear that if an employer compels attendance at a social or recreational event, then an injury during a social or recreational activity will be found to be compensable. But it has taken over 40 years for a case to get to the Supreme Court which defines what constitutes a social and recreational activity in the first place, and what sort of activities satisfy the standard of proof of a benefit beyond improvement of health and morale. Last week’s Supreme Court decision in Goulding v. NJ Friendship House, Inc., (A-48-19) provides very helpful answers.The key facts are simple. Goulding was an employee of North Je

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