The following excerpt is from Capizzi v. Southern Dist. Reporters, Inc., 459 N.E.2d 847, 471 N.Y.S.2d 554, 61 N.Y.2d 50 (N.Y. 1984):
Given the expanded theory of compensability with respect to injuries sustained by traveling employees involving incidents other than dressing or bathing, it is difficult [61 N.Y.2d 54] to reconcile a compensation award to an employee who, when returning to her hotel after dinner, slipped and fell on a sidewalk (Matter of Schreiber v. Revlon Prods. Corp., supra ) with the denial of an award to claimant in the present matter, who slipped and fell in a hotel bathtub in preparation for her return to her place of employment in New York City. Both employees sent by their employers on a business trip were removed from their normal environments, thereby increasing the risk of injury; and, as a result, were injured while engaged in "personal acts" attendant to their employment, although not participating in the actual duties of their employment.
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