In the Matter of the Claim of Bertha Scholtzhauer, Respondents, Against C. & L. Lunch Company…

Summary

The New York Court of Appeals reversed the Appellate Division’s affirmation of a workers’ compensation award to the dependents of Irma Scholtzhauer, holding that her murder did not arise out of her employment. The Court explained that for a compensation claim the injury must be a natural incident of the work and a risk inherent to the employment, which a personal‑motivation homicide is not.