Adcock v. Illinois Workers’ Compensation Comm’n

Illinois Appellate Court
Civil Court
Workers' Compensation
Citation
Case Number: 
2015 IL App (2d) 130884WC
Decision Date: 
Friday, August 14, 2015
District: 
2d Dist.
Division/County: 
McHenry Co., WC Div.
Holding: 
Reversed and remanded.
Justice: 
HOLDRIDGE
Claimant employee injured knee while working as a welder. Workers' Compensation Commission reversed arbitrator and found that claimant failed to prove he sustained workplace accident that arose out of his employment. Claimant established entitlement to benefits under neutral risk principles. Commission should not award benefits for injuries caused by everyday activities, even if employee was ordered to perform them as part of his job duties, unless employee's job required him to perform those activities more frequently than members of general public or in manner that increased risk. This is a "neutral risk" analysis. (HOFFMAN and HUDSON, concurring; STEWART, specially concurring.)