Illinois Court Says “Ordinary” Reaching Activity is Nevertheless Risk of Employment

Acknowledging that there are three categories of risk to which an employee may be exposed: (1) risks distinctly associated with her employment; (2) personal risks; and (3) neutral risks which have no particular employment or personal characteristics, an Illinois appellate court recently held that a parts inspector’s action of reaching into a long, narrow box to retrieve a small part was a risk associated with the employment and a shoulder injury that occurred as a result of the inspector’s action arose from the employment in spite of the fact that the same sort of activity was relatively common among the general public [ Young v. Illinois Workers’ Comp. Comm’n, 2014 IL App (4th) 130392WC, 2014 Ill. App. LEXIS 498 (July 7, 2014)]. Reversing a decision by the circuit court that had in turn affirmed a decision of the state’s Industrial Commission denying workers’ compensation benefits in the case, the court held an earlier finding that the inspector had only been exposed to a neutral risk was against the manifest weight of the evidence.