Illinois: Minor Deviation Results in No Recovery for Trip and Fall Injuries

Where a university employee tripped and fell as she tried to step over a chain barrier outside the university’s personnel department, where she had intended to turn in her semi-weekly timecard, her injury claim was not compensable, held an Illinois appellate court. Noting that the Commission found the employee’s decision to stray from the sidewalk “exposed her to an unnecessary danger entirely separate from her employment responsibilities,” the appellate court discounted the employee’s contention that the act that caused her injury was one the university might reasonably expect her to perform, the appellate court approved of the Commission’s reliance upon Dodson v. Industrial Comm’n, 308 Ill. App. 3d 572 (1999).

Thomas A. Robinson, J.D., the co-Editor-in-Chief and Feature National Columnist for the LexisNexis Workers’ Compensation eNewsletter, is co-author of Larson’s Workers’ Compensation Law(LexisNexis).

LexisNexis Online Subscribers: Citations below link to Lexis Advance.

See Purcell v. Illinois Workers’ Comp. Comm’n, 2021 IL App (4th) 200359WC, 2021 Ill. App. LEXIS 206 (Apr. 27, 2021)

See generally Larson’s Workers’ Compensation Law, § 17.01.

Source: Larson’s Workers’ Compensation Law, the nation’s leading authority on workers’ compensation law

For a more detailed discussion of the case, see

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