In Buckley v. American Fast Freight, Inc., the supreme court held that expressly prohibited activities do not fall within the Alaska Workers’ Compensation Act’s definition of “arising out of and in the course of employment.” Buckley worked for Labor Ready, Inc., a temporary employment service. Through Labor Ready, he sometimes worked for American Fast Freight, Inc. While working at American Fast Freight, Buckley attempted to help other employees dislodge a truck that was stuck in snow. In doing so, he got caught in a wheel and ultimately lost his arm. He brought a negligence action against American Fast Freight. The superior court granted summary judgment, finding that the exclusive liability provision of the Alaska Workers’ Compensation Act barred the action. The finding was based in part on the conclusion that Buckley’s injury arose out of and in the course of employment. In its analysis of the issue, the court found that the injury was reasonably foreseeable, and there was a strong nexus between Buckley’s actions and the employment. The court deemed immaterial several facts showing that Buckley’s actions resulting in the accident were prohibited by the employer, including a contract between American Fast Freight and Labor Ready. The supreme court reversed the summary judgment ruling and found that, based on facts conceded for the purposes of the summary judgment motion, the actions leading to the accident were outside the scope of employment. The statutory definition of “arising out of and in the course of employment” includes activities performed at the direction or under the control of the employer and activities sanctioned by the employer. As such, the supreme court reasoned that activities expressly prohibited by an employer are not within the scope of employment. The fact that Buckley’s actions violated the contract between Labor Ready and American Fast Freight was material to determining whether his actions arose out of the course of employment. Reversing and remanding the lower court’s grant of summary judgment, the supreme court held that expressly prohibited activities are not within the course and scope of employment as a matter of law.
 444 P.3d 139 (Alaska 2019).