Comp act doesn't cover manager's back injury while bending to reach satchel

An employee fails to show an increased risk of injury when he simply reaches for his satchel.

Case name: Mata v. Dial Corp., 17 ILWCLB 37 (Ill. W.C. Comm. 2009).

Ruling: The Illinois Workers' Compensation Commission denied benefits to an employee who injured his back while bending over to pick up his satchel from underneath his desk.

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What it means: Where an employee simply bends over to reach for his satchel under his desk, without actually lifting his satchel, and feels the sudden onset of pain, he has failed to show an increased risk of injury under the Workers' Compensation Act.

Summary: A manager testified that he arrived at work, entered his office, and placed his satchel under his desk. After a meeting, he reached for his bag and felt a pop and severe pain in his back. The commission noted that the employee's job did not entail regular or significant bending or lifting. The employee had not even lifted his satchel yet. The commission noted bending is an every day, normal activity and the employee did not show any increased risk.

The satchel was heavy and contained a pad the manager needed for his next meeting. The commission pointed out that had he grabbed the satchel, and lifted and twisted it awkwardly to get the pad out when the injury occurred, then the lifting may have been considered an increased risk of employment. But he testified, and the medical records supported, that he simply bent over without lifting the satchel. The commission denied benefits.

June 1, 2009

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