In an unpublished Court of Appeals decision, Beus v Broad, Vogt & Conant, Inc., (case #258995, 8/3/06), the Court of Appeals, in a 2-1 decision, denied benefits to an employee who was injured and killed in a car accident while transporting his family to their new home in Mexico. Plaintiff, a resident of Michigan, was hired by the Broad group to fill a position in Mexico. The Broad group agreed to pay for certain relocation expenses incurred by Mr. Beus and his family. After accepting the job offer, Mr. Beus left his family in Michigan and moved to Mexico. Once his children finished the school year, the family’s home in Michigan was sold and Mr. Beus’ wife and four children temporarily relocated to plaintiff’s parent’s home in Arizona. On a later date, Mr. Beus flew from Mexico to Arizona. He met with a potential client and performed other business related activities. The next day, Mr. Beus and his family drove from Arizona to Mexico. They stayed overnight at a motel in Mexico on the way to their home in a different city in Mexico. The following morning, Mr. Beus’ vehicle was involved in an accident. Mr. Beus sustained injuries, from which he later died. The magistrate denied benefits on the basis that the major purpose of relocating plaintiff’s family to Mexico was social or recreational under MCL 418.301(3). On appeal, the Workers’ Compensation Appellate Commission reversed, finding that Mr. Beus was on a “business trip”. The Appellate Commission noted that Mr. Beus had returned to Arizona for two business related purposes: (1) making a sales call on a potential client; and (2) traveling, at his employer’s expense, to his Mexico residence with his family. Therefore, the Appellate Commission concluded that Mr. Beus’ injuries and death arose out of and in the course of his employment and awarded benefits. The Court of Appeals reversed the Appellate Commission’s decision and reinstated the magistrate’s denial of benefits. The Court of Appeals agreed with the magistrate that the “major purpose” of the activity in which Mr. Beus was engaged at the time of the injury had shifted from a business purpose to a social or recreational purpose.