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Okafor, 225 Md. App. 279, 286 (2015). It requires the fact-finder to consider “the entire
sphere and period of employment . . . and also whether the employee has placed himself
outside his employment, and, if so, how far.” Proctor, 228 Md. App. at 588 (quoting
Okafor, 225 Md. App. at 286). To arise in the course of employment, injuries need not
result from “actual manipulation of the tools of work” or be sustained during “the exact
hours of work.” Livering, 374 Md. at 577 (quoting Wade, 345 Md. at 12 n.6). They need
only arise “within the time and space boundaries of the employment, and in the course of
an activity whose purpose is related to the employment.” Wade, 345 Md. at 11.
In Montgomery County v. Smith, our Court elaborated on the requisite relationship
between the injury-causing activity and employment with an excerpt from Professor Arthur
Larson’s treatise:
When seeking for a link by which to connect an activity with the
employment, one has gone a long way as soon as one has placed the activity
physically in contact with the employment environment, and even further
when one has associated the time of the activity somehow with the
employment. This done, the exact nature and purpose of the activity itself
does not have to bear the whole load of establishing work connection, and
consequently the employment-connection of that nature and purpose does
not have to be as conspicuous as it otherwise might. Conversely, if the . . .
activity takes place on some distant vacant lot, several hours after the day’s
work has ceased, some independently convincing association with the
employment must be built up to overcome the initial presumption of
disassociation with the employment established by the time and place factors.
144 Md. App. at 565–66 (emphasis added) (quoting 4 Arthur Larson, Workers’
Compensation Law § 22.03 (2001)).
In contrast to the requirement that an injury arise “out of” employment, which focuses
on the existence of a connection between the injury and the injured worker’s employment,