Supreme Court Expressly Rejects 'Dual-Purpose' Doctrine for Compensability

A divided Ohio Supreme Court this week clarified that the doctrine of dual intent, or dual purpose, has no place in the state's workers' compensation system. The court said it had implicitly rejected the doctrine – which arose from New York's common law and has been adopted by several other states – nearly 70 years ago. In a decision released Tuesday, the court flat-out said the idea cannot be used in determining the compensability of a worker's car accident. Generally, any accident while the worker is traveling to or from work will not be compensable, the court e...