The Washington State Supreme Court ruled in *Azorit-Wortham v. Department of Labor & Industries* (Wash. 2025), a case that addresses the intersection of COVID-19 infections and workers' compensation coverage for employees who travel as part of their job duties. The opinion, filed Nov. 6, 2025, involves Alaska Airlines flight attendant Lisa Azorit-Wortham's claim that she contracted COVID-19 as an occupational disease during her employment in March 2020.
Ms. Azorit-Wortham worked as a flight attendant for Alaska Airlines when she contracted COVID-19 in March 2020, during the early stages of the pandemic. She filed a claim under Washington's Industrial Insurance Act, arguing that her illness met the definition of an occupational disease because she likely contracted the virus either while working or while traveling for work purposes. The Industrial Insurance Act, codified in Title 51 RCW, provides coverage to workers who suffer job-related injuries or develop occupational diseases arising from their employment.
The central legal question in the case involved the application of the traveling employee doctrine to occupational disease claims. This doctrine traditionally applies when workers are injured while traveling for work, extending workers' compensation coverage beyond the physical workplace to include work-related travel. Ms. Azorit-Wortham argued that this doctrine should also apply to occupational diseases contracted during work-related travel.
At the trial court level, the judge ruled that the traveling employee doctrine does apply when an employee contracts an occupational disease while traveling for work. Despite objections from Alaska Airlines, the trial court instructed the jury that coverage under the Industrial Insurance Act included the time Ms. Azorit-Wortham spent traveling for work. The jury ultimately found in favor of Ms. Azorit-Wortham, determining that her COVID-19 infection qualified for workers' compensation benefits.
Alaska Airlines appealed the trial court's decision to the Washington Court of Appeals. The appeals court held that the trial court erred in its application of the traveling employee doctrine to occupational disease claims. This intermediate appellate ruling created uncertainty about whether the doctrine could be extended beyond traditional injury cases to cover diseases contracted during work-related travel.
The case then proceeded to the Washington State Supreme Court, which heard the matter en banc, meaning all justices participated in the decision. Justice Mungia authored the opinion for the high court, though the complete text of the ruling addressing the court's final determination was not available in the provided excerpts.
The timing of Ms. Azorit-Wortham's illness is significant, as she contracted COVID-19 in March 2020, when health authorities were still learning about transmission patterns and workplace safety protocols were evolving rapidly. Flight attendants faced unique exposure risks during this period, working in enclosed aircraft environments with passengers from multiple locations while air travel continued despite growing health concerns.
This case represents one of many legal challenges that emerged as workers sought compensation for COVID-19 infections allegedly contracted in workplace settings. The aviation industry, in particular, faced numerous claims from employees who argued that their job duties placed them at heightened risk of exposure to the virus.
The Industrial Insurance Act's definition of occupational disease typically requires proof that the disease arose naturally and proximately out of employment. For infectious diseases like COVID-19, establishing this connection can be challenging given the widespread community transmission that occurred during the pandemic.
The traveling employee doctrine has traditionally provided broader workers' compensation coverage for employees whose job duties require travel, recognizing that their exposure to workplace risks extends beyond a fixed workplace location. Flight attendants, whose work inherently involves travel, represent a category of workers for whom this doctrine has particular relevance.
The legal implications of this case extend beyond the aviation industry to other sectors where employees travel as part of their job duties. The court's interpretation of how the traveling employee doctrine applies to occupational disease claims could influence future workers' compensation cases involving infectious diseases contracted during work-related travel.
For Alaska Airlines and other employers in the transportation industry, the ruling provides guidance on their potential liability for workers' compensation claims related to infectious diseases contracted by traveling employees. The decision may also influence how employers approach safety protocols and risk assessment for employees whose work involves travel.
The case highlights ongoing legal questions about workers' compensation coverage during public health emergencies and the challenges of proving occupational causation for infectious diseases with multiple potential sources of exposure. As workplaces continue to adapt to post-pandemic realities, courts will likely continue to address similar questions about the scope of workers' compensation coverage for disease-related claims.