McAllister v. Illinois Workers’ Compensation Commission

Illinois Supreme Court
Civil Court
Workers' Compensation
Citation
Case Number: 
2020 IL 124848
Decision Date: 
Thursday, September 24, 2020
District: 
1st Dist.
Division/County: 
Cook Co.
Holding: 
Circuit court reversed; remanded with directions.
Justice: 
NEVILLE

Claimant injured his knee while working as a sous-chef. Arbitrator awarded workers' compensation benefits to him, but Illinois Workers' Compensation Commission reversed, finding that the injury did not "arise out of" his employment.  Commission's finding is against manifest weight of evidence. Knee injury arose out of Claimant's employment because at the time of his injury, when he was searching in the walk-in cooler for a coworker's misplaced pan of carrots, he was at work performing an act his employer might reasonably expect him to perform incident to his assigned job duties which included arranging the walk-in cooler. Once it is established that the injury is work related, claimant is not required to present additional evidence for work-related injuries that are caused by common bodily movements or everyday activities such as bending, twisting, reaching, or standing up for a kneeling position. (A. BURKE, KILBRIDE, GARMAN, KARMEIER, and THEIS, concurring.)