Andrea Cotton sued a daycare operator after one of its employees crossed the median during her lunch-break return drive and crashed into Cotton while scrolling through her phone to call her manager about being late. The Supreme Court of Georgia used the case to decide how Georgia courts should analyze employer liability when an employee causes a wreck while commuting or returning from lunch but is also doing something arguably work-related. The Court vacated the Court of Appeals decision and remanded. It held that Georgia does not recognize a free-standing "special circumstances exception" to the going-and-coming rule; the only real question is the ordinary respondeat-superior inquiry of whether the employee was acting in furtherance of the employer's business and within the scope of employment at the moment of the tort. The reasoning rejected the Court of Appeals' multi-factor exception framework and required the lower court to apply the standard scope-and-furtherance analysis instead.