In the recent decision of Hersh v. County of Morris, the New Jersey Supreme Court tightened the limits of workers’ compensation benefits available to employees injured in the workplace. In this case, a Morris County employee was hit by a car when attempting to get to her office from a parking garage located across the street. Her employer, the County of Morris, did not control the parking lot, though the County did rent parking spots there for use by its employees. In overturning a workers’ compensation award to the employee, the Supreme Court relied on the issue of employer control over the employee. Thus, because the County did not control the parking lot, the employee was not deemed to be within the scope of her employment at the time of injury. As a result, the Supreme Court found that the employee was not entitled to workers’ compensation benefits.