Supreme Court of Missouri / Apr 14, 2020
Lucille Schoen, Appellant, vs. Mid-Missouri Mental Health Center and Treasurer of the State of Missouri - Custodian of the Second Injury Fund, Respondents.
Lucille Schoen appealed the Labor and Industrial Relations Commission's denial of workers' compensation benefits for injuries she sustained after being tripped at a doctor's office. Schoen argued these injuries were a natural consequence of an earlier work-related insecticide exposure, which necessitated the doctor's visit. The Missouri Supreme Court affirmed the Commission's decision, holding that the accidental tripping did not arise out of and in the course of employment because the risk was one she would have been equally exposed to outside of work, failing the statutory causation test. Consequently, her claim against the Second Injury Fund was also denied.