Washington’s Supreme Court has ruled that flight attendants who catch COVID-19 while traveling for work can qualify for workers’ comp – reshaping pandemic-era claims.
That’s the key takeaway from the court’s November 6, 2025, decision in Azorit-Wortham v. Department of Labor & Industries and Alaska Airlines, a case closely watched by insurance professionals and employers alike. At the heart of the dispute was whether workers’ compensation in Washington covers employees who contract diseases such as COVID-19 during work-related travel – a question with significant implications for claims handling and policy interpretation.
Lisa Azorit-Wortham, a flight attendant for Alaska Airlines, tested positive for COVID-19 in early April 2020 after working eight flights – including four transcontinental trips – between March 16 and March 27, 2020. During this period, neither crew nor passengers were required to wear masks, and Azorit-Wortham testified that she had minimal contact with others outside of work. She filed a workers’ compensation claim, arguing that her illness met the definition of an “occupational disease” under Washington’s Industrial Insurance Act because it arose naturally and proximately from the distinctive conditions of her employment.
Initially, the Department of Labor and Industries sided with Azorit-Wortham and granted her claim. However, Alaska Airlines appealed, and an administrative law judge reversed the decision, finding that her COVID-19 did not qualify as an occupational disease. The Board of Industrial Insurance Appeals upheld that ruling, prompting Azorit-Wortham to take her case to Pierce County Superior Court. There, a jury was asked to decide whether her illness should be covered.
A central issue at trial was the application of the “traveling employee doctrine.” This doctrine holds that employees are covered by workers’ compensation throughout the duration of a business trip, including time spent traveling, staying in hotels, and eating meals. Alaska Airlines objected to the trial court’s instruction on this doctrine, arguing that it should only apply to sudden injuries, not to diseases that develop over time. The airline contended that the doctrine conflicted with the statutory definition of occupational disease, which requires that the illness arise from distinctive conditions of employment and not from everyday life.
The jury ultimately found in favor of Azorit-Wortham. Alaska Airlines appealed again, and the Court of Appeals reversed the verdict, holding that the traveling employee doctrine does not apply to occupational diseases and sending the case back for a new trial.
The Washington Supreme Court, however, disagreed with the appellate court’s interpretation. In its decision, the Supreme Court stated that the traveling employee doctrine does apply to occupational diseases. The justices clarified that the doctrine merely defines the period during which coverage is in effect, not the substantive requirements for what constitutes an occupational disease. The court emphasized that the statutory definition – requiring the disease to arise naturally and proximately from the worker’s employment – remains unchanged. The jury was properly instructed that it had to find Azorit-Wortham’s COVID-19 illness met this definition in order to award coverage.
The court also noted that insurance statutes, including workers’ compensation laws, are to be interpreted liberally in favor of coverage where possible, consistent with the remedial purpose of the law. The Supreme Court reversed the Court of Appeals and remanded the case for further proceedings to determine whether substantial evidence supported the jury’s verdict.
For insurance professionals and employers, the decision provides important guidance. When employees travel for work, workers’ compensation coverage in Washington extends to the entire trip, including the risk of contracting diseases like COVID-19, provided the job’s conditions are the likely cause. The case now returns to the Court of Appeals for a final review of the evidence, but the Supreme Court’s ruling sets a clear precedent for how similar claims should be evaluated.
As pandemic-era claims continue to emerge, this decision underscores the evolving landscape of workers’ compensation and the importance of understanding how established doctrines apply to new workplace risks. For claims handlers and risk managers, the boundaries of coverage for traveling employees are now more clearly defined – at least in Washington State.
