Miguel Contreras — ADJ14628369

Applicant Miguel Contreras, a 23-year-old Driving Logistics Associate/Driver for Shift Technologies, was injured as a passenger in a co-worker's vehicle during a head-on collision approximately two minutes after swapping parking spots with that co-worker. He had parked his own car in the employer's customer lot, then accepted the co-worker's street parking spot and rode along while the co-worker searched for new parking. The WCJ found the injury arose out of and in the course of employment (AOE/COE) under the personal comfort doctrine. The WCAB granted defendant's petition for reconsideration but, as its Decision After Reconsideration, affirmed the AOE/COE finding, holding applicant's conduct was an act of personal convenience reasonably contemplated by his employment. The Board amended the F&A to specifically find a right hand injury, defer the issue of additional body parts, and defer the issue of whether defendant's attorney (Littler Mendelson) is subject to sanctions for impugning the integrity of the WCAB and its judge.