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Missouri Supreme Court Limits What Constitutes an Accidental Injury in Work Comp

Christopher D. Vanderbeek

Christopher D. Vanderbeek




The Missouri Supreme Court recently held that an employee who was injured while turning to walk away from a coffeemaker was not entitled to workers’ compensation benefits under Missouri law.

In Johme v. St. John’s Mercy Healthcare, Johme worked for St. John’s as a billing representative. While clocked into work, Johme made a pot of coffee. As she turned to walk back to her desk, Johme’s foot slipped off her shoe, causing her to twist her ankle and fall on her right side. The court noted that Johme was wearing “sandals with a thick heel and a flat bottom.” It also noted the following:

“There were no irregularities or hazards on the kitchen’s floor. The floor was not wet, and there was not any trash on the floor.”

An administrative law judge denied Johme’s claim for workers’ compensation benefits on the grounds that “she was not performing her [work] duties at the time of her fall at work,” and she “just fell and … would have been exposed to the same hazard or risk” outside of work. Continue reading »