Robert A. Allen, Plaintiff v. Industrial Commission, Board of Review, Jer Ken, Inc., State Insurance Fund And…

Summary

The court vacated the Commission’s denial of benefits and remanded for additional findings on legal and medical causation. It held that an injury may occur “by accident” when it is unexpected or unintended, even if caused by an ordinary workplace exertion, and rejected requiring an unusual event as part of the accident analysis. Because the claimant had a preexisting back condition, he still had to prove that his work exertion exceeded ordinary nonemployment exertion and medically caused or contributed to the injury. Hall, C.J., concurring in part and dissenting in part, agreed with remand but rejected the court’s unexpected-result definition of accident.