neutral-risk analysis in Illinois

15 Illinois opinions name it 2 courts 2015–2026 1 in the last five years

The cases below were cited by Illinois courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (18)

Case	Followed	Cited
Young v. Illinois Workers' Compensation Commissiongreen illappct · 2014 · cited in 5 Illinois opinions naming this issue, 2016–2017 2 sentences 2017See Young v. Illinois Workers’ Compensation Comm’n, 2014 IL App (4th) 130392WC, ¶ 23 , 13 N.E.3d 1252 (“when a claimant is injured due to an employment-related risk * it is unnecessary to perform a neutral-risk analysis”). 2017See, e.g., Young v. Illinois Workers’ Compensation Comm’n, 2014 IL App (4th) 130392WC, ¶ 23 , 13 N.E.3d 1252 (“when a claimant is injured due to an employment-related risk * it is unnecessary to perform a neutral-risk analysis”). ¶ 40 Injuries arising out of neutral risks, which have no particular employment or personal characteristics, are generally not compensable.	5	5
Orsini v. Industrial Commissiongreen ill · 1987 · cited in 5 Illinois opinions naming this issue, 2015–2019 2 sentences 2019Significantly, it stated that liability is found to exist under the Act when the employee's injury "was directly related to the specific duties of employment." Id. at 47-48 , 109 Ill.Dec. 166 , 509 N.E.2d 1005 . ¶ 61 We find Orsini , given its emphasis on the duties of a claimant's employment 452 540 relative to risk, is consistent with our unanimous decision in Young and the following determination in that case: "[W]hen a claimant is injured due to an employment-related risk-a risk distinctly associated with his or her employment-it is unnecessary to perform a neutral-risk analysis to deter 2019Significantly, it stated that liability is found to exist under the Act when the employee's injury "was directly related to the specific duties of employment." Id. at 47-48 , 109 Ill.Dec. 166 , 509 N.E.2d 1005 . ¶ 61 We find Orsini , given its emphasis on the duties of a claimant's employment 452 540 relative to risk, is consistent with our unanimous decision in Young and the following determination in that case: "[W]hen a claimant is injured due to an employment-related risk-a risk distinctly associated with his or her employment-it is unnecessary to perform a neutral-risk analysis to deter	3	5
Kemp v. Industrial Commissiongreen illappct · 1994 · cited in 6 Illinois opinions naming this issue, 2015–2020 2 sentences 2020The appellate court majority held that claims involving common bodily movements and everyday activities should be analyzed under the Caterpillar Tractor test, without engaging in additional neutral-risk analysis. 2019 IL App (1st) 162747WC, ¶¶ 34-73 ; see, e.g., Steak ’n Shake, 2016 IL App (3d) 150500WC, ¶¶ 37-38 (waitress who injured her hand wiping down table suffered an employment-related injury because at the time of the occurrence she was engaging in an activity her employer might reasonably expect her to perform in the fulfillment of her job duties, and therefore, it was unnecessary to e 2019For example, in Kemp , 264 Ill.	2	6
Brady v. Louis Ruffolo & Sons Construction Co.green ill · 1991 · cited in 3 Illinois opinions naming this issue, 2019–2020 2 sentences 2020Similarly, and for the same reasons, we need not address the employer’s argument relating to the positional risk doctrine, which this court has declined to adopt (Brady, 143 Ill. 2d at 552-53 ) and which only applies to neutral risks. 2019See Brady , 143 Ill. 2d at 552 , 161 Ill.Dec. 275 , 578 N.E.2d 921 .	2	3
Campbell \66\" Expressgreen · 1980 · cited in 3 Illinois opinions naming this issue, 2019–2020 2 sentences 2020See, e.g., Campbell “66” Express, Inc. v. Industrial Comm’n, 83 Ill. 2d 353, 357 (1980) (truck-driver claimant’s travel requirements subjected him to risks of injury from tornadoes beyond that to which the general public was exposed); Beecher Wholesale Greenhouse, Inc. v. Industrial Comm’n, 170 Ill. 2019See Brady , 143 Ill. 2d at 545 , 161 Ill.Dec. 275 , 578 N.E.2d 921 (truck crashed into the employer's building); Illinois Bell Telephone Co. v. Industrial Comm'n , 131 Ill. 2d 478 , 481, 137 Ill.Dec. 658 , 546 N.E.2d 603 , 604 (1989) (slip and fall in a mall common area); Caterpillar Tractor , 129 Ill. 2d at 56 , 133 Ill.Dec. 454 , 541 N.E.2d 665 (stepping off a curb); Doyle v. Industrial Comm'n , 95 Ill. 2d 103 , 104-05, 69 Ill.Dec. 93 , 447 N.E.2d 310 , 311 (1983) (vehicle accident while exiting the employer's parking lot); Campbell "66" Express , 83 Ill. 2d at 355 , 47 Ill.Dec. 730 , 415 N.	2	3
Karastamatis v. Industrial Commissiongreen illappct · 1999 · cited in 3 Illinois opinions naming this issue, 2016–2019 2 sentences 2019App. 3d at 209 , 238 Ill.Dec. 915 , 713 N.E.2d 161 . 10 Because such risks are not faced by members of the general public, we do not need to conduct a neutral risk analysis in such cases. 2019App. 3d at 209 , 238 Ill.Dec. 915 , 713 N.E.2d 161 . 10 Because such risks are not faced by members of the general public, we do not need to conduct a neutral risk analysis in such cases.	2	3
Hansel & Gretel Day Care Center v. Industrial Commissiongreen illappct · 1991 · cited in 2 Illinois opinions naming this issue, 2019–2019 2 sentences 2019Infra ¶¶ 96-97; see Hansel & Gretel Day Care Center v. Industrial Comm'n , 215 Ill. 2019Infra ¶¶ 96-97; see Hansel & Gretel Day Care Center v. Industrial Comm’n, 215 Ill.	2	2
Caterpillar Tractor Co. v. Industrial Commissiongreen ill · 1989 · cited in 5 Illinois opinions naming this issue, 2015–2019 2 sentences 2019See Brady , 143 Ill. 2d at 545 , 161 Ill.Dec. 275 , 578 N.E.2d 921 (truck crashed into the employer's building); Illinois Bell Telephone Co. v. Industrial Comm'n , 131 Ill. 2d 478 , 481, 137 Ill.Dec. 658 , 546 N.E.2d 603 , 604 (1989) (slip and fall in a mall common area); Caterpillar Tractor , 129 Ill. 2d at 56 , 133 Ill.Dec. 454 , 541 N.E.2d 665 (stepping off a curb); Doyle v. Industrial Comm'n , 95 Ill. 2d 103 , 104-05, 69 Ill.Dec. 93 , 447 N.E.2d 310 , 311 (1983) (vehicle accident while exiting the employer's parking lot); Campbell "66" Express , 83 Ill. 2d at 355 , 47 Ill.Dec. 730 , 415 N. 2019See Brady , 143 Ill. 2d at 545 , 161 Ill.Dec. 275 , 578 N.E.2d 921 (truck crashed into the employer's building); Illinois Bell Telephone Co. v. Industrial Comm'n , 131 Ill. 2d 478 , 481, 137 Ill.Dec. 658 , 546 N.E.2d 603 , 604 (1989) (slip and fall in a mall common area); Caterpillar Tractor , 129 Ill. 2d at 56 , 133 Ill.Dec. 454 , 541 N.E.2d 665 (stepping off a curb); Doyle v. Industrial Comm'n , 95 Ill. 2d 103 , 104-05, 69 Ill.Dec. 93 , 447 N.E.2d 310 , 311 (1983) (vehicle accident while exiting the employer's parking lot); Campbell "66" Express , 83 Ill. 2d at 355 , 47 Ill.Dec. 730 , 415 N.	1	5
INST. OF TECH. RES. v. Industrial Com'ngreen illappct · 2000 · cited in 3 Illinois opinions naming this issue, 2015–2019 2 sentences 2019This court has stated that "[n]eutral risks include stray bullets, dog bites, lunatic attacks, lightning strikes, bombing, and hurricanes." Illinois Institute of Technology Research Institute v. Industrial Comm'n , 314 Ill. 2019This court has stated that “[n]eutral risks include stray bullets, dog bites, lunatic attacks, lightning strikes, bombing, and hurricanes.” Illinois Institute of Technology Research Institute v. Industrial Comm’n, 314 Ill.	1	3
Komatsu Dresser Co. v. Industrial Commissiongreen illappct · 1992 · cited in 2 Illinois opinions naming this issue, 2019–2020 2 sentences 2019Instead, we applied a neutral risk analysis and affirmed the Commission's award of benefits only after we concluded that the evidence supported a "reasonable inference that the claimant's acts of bending required by his work exposed [him] to a greater degree of risk than that of the general public." Id. at 788 , 176 Ill.Dec. 641 , 601 N.E.2d 1339 . 2019Instead, we applied a neutral risk analysis and affirmed the Commission's award of benefits only after we concluded that the evidence supported a "reasonable inference that the claimant's acts of bending required by his work exposed [him] to a greater degree of risk than that of the general public." Id. at 788 , 176 Ill.Dec. 641 , 601 N.E.2d 1339 .	1	2
Thurber v. Industrial Commissiongreen ill · 1971 · cited in 2 Illinois opinions naming this issue, 2019–2019 2 sentences 2019See Brady , 143 Ill. 2d at 545 , 161 Ill.Dec. 275 , 578 N.E.2d 921 (truck crashed into the employer's building); Illinois Bell Telephone Co. v. Industrial Comm'n , 131 Ill. 2d 478 , 481, 137 Ill.Dec. 658 , 546 N.E.2d 603 , 604 (1989) (slip and fall in a mall common area); Caterpillar Tractor , 129 Ill. 2d at 56 , 133 Ill.Dec. 454 , 541 N.E.2d 665 (stepping off a curb); Doyle v. Industrial Comm'n , 95 Ill. 2d 103 , 104-05, 69 Ill.Dec. 93 , 447 N.E.2d 310 , 311 (1983) (vehicle accident while exiting the employer's parking lot); Campbell "66" Express , 83 Ill. 2d at 355 , 47 Ill.Dec. 730 , 415 N. 2019See Brady , 143 Ill. 2d at 545 , 161 Ill.Dec. 275 , 578 N.E.2d 921 (truck crashed into the employer's building); Illinois Bell Telephone Co. v. Industrial Comm'n , 131 Ill. 2d 478 , 481, 137 Ill.Dec. 658 , 546 N.E.2d 603 , 604 (1989) (slip and fall in a mall common area); Caterpillar Tractor , 129 Ill. 2d at 56 , 133 Ill.Dec. 454 , 541 N.E.2d 665 (stepping off a curb); Doyle v. Industrial Comm'n , 95 Ill. 2d 103 , 104-05, 69 Ill.Dec. 93 , 447 N.E.2d 310 , 311 (1983) (vehicle accident while exiting the employer's parking lot); Campbell "66" Express , 83 Ill. 2d at 355 , 47 Ill.Dec. 730 , 415 N.	1	2
Illinois Bell Telephone Co. v. Industrial Commissiongreen ill · 1989 · cited in 2 Illinois opinions naming this issue, 2019–2019 2 sentences 2019See Brady , 143 Ill. 2d at 545 , 161 Ill.Dec. 275 , 578 N.E.2d 921 (truck crashed into the employer's building); Illinois Bell Telephone Co. v. Industrial Comm'n , 131 Ill. 2d 478 , 481, 137 Ill.Dec. 658 , 546 N.E.2d 603 , 604 (1989) (slip and fall in a mall common area); Caterpillar Tractor , 129 Ill. 2d at 56 , 133 Ill.Dec. 454 , 541 N.E.2d 665 (stepping off a curb); Doyle v. Industrial Comm'n , 95 Ill. 2d 103 , 104-05, 69 Ill.Dec. 93 , 447 N.E.2d 310 , 311 (1983) (vehicle accident while exiting the employer's parking lot); Campbell "66" Express , 83 Ill. 2d at 355 , 47 Ill.Dec. 730 , 415 N. 2019See Brady , 143 Ill. 2d at 545 , 161 Ill.Dec. 275 , 578 N.E.2d 921 (truck crashed into the employer's building); Illinois Bell Telephone Co. v. Industrial Comm'n , 131 Ill. 2d 478 , 481, 137 Ill.Dec. 658 , 546 N.E.2d 603 , 604 (1989) (slip and fall in a mall common area); Caterpillar Tractor , 129 Ill. 2d at 56 , 133 Ill.Dec. 454 , 541 N.E.2d 665 (stepping off a curb); Doyle v. Industrial Comm'n , 95 Ill. 2d 103 , 104-05, 69 Ill.Dec. 93 , 447 N.E.2d 310 , 311 (1983) (vehicle accident while exiting the employer's parking lot); Campbell "66" Express , 83 Ill. 2d at 355 , 47 Ill.Dec. 730 , 415 N.	1	2
Jones v. Industrial Commissiongreen ill · 1980 · cited in 2 Illinois opinions naming this issue, 2019–2019 2 sentences 2019See Brady , 143 Ill. 2d at 545 , 161 Ill.Dec. 275 , 578 N.E.2d 921 (truck crashed into the employer's building); Illinois Bell Telephone Co. v. Industrial Comm'n , 131 Ill. 2d 478 , 481, 137 Ill.Dec. 658 , 546 N.E.2d 603 , 604 (1989) (slip and fall in a mall common area); Caterpillar Tractor , 129 Ill. 2d at 56 , 133 Ill.Dec. 454 , 541 N.E.2d 665 (stepping off a curb); Doyle v. Industrial Comm'n , 95 Ill. 2d 103 , 104-05, 69 Ill.Dec. 93 , 447 N.E.2d 310 , 311 (1983) (vehicle accident while exiting the employer's parking lot); Campbell "66" Express , 83 Ill. 2d at 355 , 47 Ill.Dec. 730 , 415 N. 2019See Brady , 143 Ill. 2d at 545 , 161 Ill.Dec. 275 , 578 N.E.2d 921 (truck crashed into the employer's building); Illinois Bell Telephone Co. v. Industrial Comm'n , 131 Ill. 2d 478 , 481, 137 Ill.Dec. 658 , 546 N.E.2d 603 , 604 (1989) (slip and fall in a mall common area); Caterpillar Tractor , 129 Ill. 2d at 56 , 133 Ill.Dec. 454 , 541 N.E.2d 665 (stepping off a curb); Doyle v. Industrial Comm'n , 95 Ill. 2d 103 , 104-05, 69 Ill.Dec. 93 , 447 N.E.2d 310 , 311 (1983) (vehicle accident while exiting the employer's parking lot); Campbell "66" Express , 83 Ill. 2d at 355 , 47 Ill.Dec. 730 , 415 N.	1	2
Eisenberg v. Industrial Commissiongreen ill · 1976 · cited in 2 Illinois opinions naming this issue, 2019–2019 2 sentences 2019See Brady , 143 Ill. 2d at 545 , 161 Ill.Dec. 275 , 578 N.E.2d 921 (truck crashed into the employer's building); Illinois Bell Telephone Co. v. Industrial Comm'n , 131 Ill. 2d 478 , 481, 137 Ill.Dec. 658 , 546 N.E.2d 603 , 604 (1989) (slip and fall in a mall common area); Caterpillar Tractor , 129 Ill. 2d at 56 , 133 Ill.Dec. 454 , 541 N.E.2d 665 (stepping off a curb); Doyle v. Industrial Comm'n , 95 Ill. 2d 103 , 104-05, 69 Ill.Dec. 93 , 447 N.E.2d 310 , 311 (1983) (vehicle accident while exiting the employer's parking lot); Campbell "66" Express , 83 Ill. 2d at 355 , 47 Ill.Dec. 730 , 415 N. 2019See Brady , 143 Ill. 2d at 545 , 161 Ill.Dec. 275 , 578 N.E.2d 921 (truck crashed into the employer's building); Illinois Bell Telephone Co. v. Industrial Comm'n , 131 Ill. 2d 478 , 481, 137 Ill.Dec. 658 , 546 N.E.2d 603 , 604 (1989) (slip and fall in a mall common area); Caterpillar Tractor , 129 Ill. 2d at 56 , 133 Ill.Dec. 454 , 541 N.E.2d 665 (stepping off a curb); Doyle v. Industrial Comm'n , 95 Ill. 2d 103 , 104-05, 69 Ill.Dec. 93 , 447 N.E.2d 310 , 311 (1983) (vehicle accident while exiting the employer's parking lot); Campbell "66" Express , 83 Ill. 2d at 355 , 47 Ill.Dec. 730 , 415 N.	1	2
Inland Steel Co. v. Industrial Commissiongreen ill · 1968 · cited in 2 Illinois opinions naming this issue, 2019–2019 2 sentences 2019See Brady , 143 Ill. 2d at 545 , 161 Ill.Dec. 275 , 578 N.E.2d 921 (truck crashed into the employer's building); Illinois Bell Telephone Co. v. Industrial Comm'n , 131 Ill. 2d 478 , 481, 137 Ill.Dec. 658 , 546 N.E.2d 603 , 604 (1989) (slip and fall in a mall common area); Caterpillar Tractor , 129 Ill. 2d at 56 , 133 Ill.Dec. 454 , 541 N.E.2d 665 (stepping off a curb); Doyle v. Industrial Comm'n , 95 Ill. 2d 103 , 104-05, 69 Ill.Dec. 93 , 447 N.E.2d 310 , 311 (1983) (vehicle accident while exiting the employer's parking lot); Campbell "66" Express , 83 Ill. 2d at 355 , 47 Ill.Dec. 730 , 415 N. 2019See Brady , 143 Ill. 2d at 545 , 161 Ill.Dec. 275 , 578 N.E.2d 921 (truck crashed into the employer's building); Illinois Bell Telephone Co. v. Industrial Comm'n , 131 Ill. 2d 478 , 481, 137 Ill.Dec. 658 , 546 N.E.2d 603 , 604 (1989) (slip and fall in a mall common area); Caterpillar Tractor , 129 Ill. 2d at 56 , 133 Ill.Dec. 454 , 541 N.E.2d 665 (stepping off a curb); Doyle v. Industrial Comm'n , 95 Ill. 2d 103 , 104-05, 69 Ill.Dec. 93 , 447 N.E.2d 310 , 311 (1983) (vehicle accident while exiting the employer's parking lot); Campbell "66" Express , 83 Ill. 2d at 355 , 47 Ill.Dec. 730 , 415 N.	1	2
Doyle v. Industrial Commissiongreen ill · 1983 · cited in 2 Illinois opinions naming this issue, 2019–2019 2 sentences 2019See Brady , 143 Ill. 2d at 545 , 161 Ill.Dec. 275 , 578 N.E.2d 921 (truck crashed into the employer's building); Illinois Bell Telephone Co. v. Industrial Comm'n , 131 Ill. 2d 478 , 481, 137 Ill.Dec. 658 , 546 N.E.2d 603 , 604 (1989) (slip and fall in a mall common area); Caterpillar Tractor , 129 Ill. 2d at 56 , 133 Ill.Dec. 454 , 541 N.E.2d 665 (stepping off a curb); Doyle v. Industrial Comm'n , 95 Ill. 2d 103 , 104-05, 69 Ill.Dec. 93 , 447 N.E.2d 310 , 311 (1983) (vehicle accident while exiting the employer's parking lot); Campbell "66" Express , 83 Ill. 2d at 355 , 47 Ill.Dec. 730 , 415 N. 2019See Brady , 143 Ill. 2d at 545 , 161 Ill.Dec. 275 , 578 N.E.2d 921 (truck crashed into the employer's building); Illinois Bell Telephone Co. v. Industrial Comm'n , 131 Ill. 2d 478 , 481, 137 Ill.Dec. 658 , 546 N.E.2d 603 , 604 (1989) (slip and fall in a mall common area); Caterpillar Tractor , 129 Ill. 2d at 56 , 133 Ill.Dec. 454 , 541 N.E.2d 665 (stepping off a curb); Doyle v. Industrial Comm'n , 95 Ill. 2d 103 , 104-05, 69 Ill.Dec. 93 , 447 N.E.2d 310 , 311 (1983) (vehicle accident while exiting the employer's parking lot); Campbell "66" Express , 83 Ill. 2d at 355 , 47 Ill.Dec. 730 , 415 N.	1	2
McAllister v. Illinois Workers' Compensation Commissiongreen ill · 2020 · cited in 1 Illinois opinions naming this issue, 2026–2026 1 sentence 2026See, e.g., Adcock v. Illinois Workers’ Compensation Comm’n, 2015 IL App (2d) 130884WC, ¶¶ 33-34 (a welder’s injury was compensable under the neutral risk analysis because his job required him to turn in a swivel chair more frequently than the general public) (overruled by McAllister, 2020 IL 124848, ¶ 64 ). 3 Plaintiff’s expert opines that by not citing any authority, Fishel did not present an effective legal argument on the “arising out of employment” element.	1	1
Beecher Wholesale Greenhouse, Inc. v. Industrial Commissiongreen illappct · 1988 · cited in 1 Illinois opinions naming this issue, 2020–2020 1 sentence 2020See, e.g., Campbell “66” Express, Inc. v. Industrial Comm’n, 83 Ill. 2d 353, 357 (1980) (truck-driver claimant’s travel requirements subjected him to risks of injury from tornadoes beyond that to which the general public was exposed); Beecher Wholesale Greenhouse, Inc. v. Industrial Comm’n, 170 Ill.	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (6)

Case	Cited	Years
O'Fallon School District No. 90 v. Industrial Commission green illappct · 2000 2 sentences 2019Id. ¶ 52 The special concurrence states that it agrees with the analysis employed in O'Fallon and finds O'Fallon distinguishable from Adcock on the basis that "the risk at issue in O'Fallon was distinctly associated with ( i.e. , 'peculiar to') the claimant's employment, rendering a neutral risk analysis unnecessary and inappropriate." Infra ¶ 100. 2019Id. ¶ 52 The special concurrence states that it agrees with the analysis employed in O’Fallon and finds O’Fallon distinguishable from Adcock on the basis that “the risk at issue in O’Fallon was distinctly associated with (i.e., ‘peculiar to’) the claimant’s employment, rendering a neutral risk analysis unnecessary and inappropriate.” Infra ¶ 100.	3	2015–2019
First Cash Financial Services v. Industrial Commission green illappct · 2006 2 sentences 2019As noted above, a neutral risk analysis is required only where the risk at issue is one "to which the general public is equally exposed." First Cash Financial Services , 367 Ill. 2019Accordingly, the risk that caused the fatal injury was peculiar to the decedent’s employment, and there was no need to perform a neutral risk analysis.6 Here, by contrast, the risk that led to the claimant’s injury 6 As noted above, a neutral risk analysis is required only where the risk at issue is one “to which the general public is equally exposed.” First Cash Financial Services, 367 Ill.	2	2019–2019
Sisbro, Inc. v. Industrial Commission green ill · 2003 2 sentences 2019We have never found a causal connection to exist between work and injury and then, in a further analytical step, denied recovery based on a 'normal daily activity exception' or a 'greater risk exception.' " 207 Ill. 2d at 211 -212 , 278 Ill.Dec. 70 , 797 N.E.2d 665 . ¶ 44 We find that it is when any of the aforementioned three categories of acts are determined to be present that the risk resulting in injury is "distinctly associated with the employment," i.e. , not a neutral risk that is subject to a neutral-risk analysis. 2019We have never found a causal connection to exist between work and injury and then, in a further analytical step, denied recovery based on a 'normal daily activity exception' or a 'greater risk exception.' " 207 Ill. 2d at 211 -212 , 278 Ill.Dec. 70 , 797 N.E.2d 665 . ¶ 44 We find that it is when any of the aforementioned three categories of acts are determined to be present that the risk resulting in injury is "distinctly associated with the employment," i.e. , not a neutral risk that is subject to a neutral-risk analysis.	2	2019–2019
The Venture-New berg Perini Stone and Webster v. Illinois Workers' Compensation Commission green ill · 2013 1 sentence 2020Specifically, the Commission found that the claimant was a traveling employee, and that as such his claim was “compensable pursuant to the traveling employee doctrine and not the neutral risk analysis *** performed by the Arbitrator.” The Commission noted that a “traveling employee” is “any employee for whom travel is an essential element of his employment.” Citing Venture-Newberg-Perini v. Illinois Workers' Compensation Commission, 2013 IL 115728 , the Commission stated that “[c]ourts generally regard employees whose duties require them to travel away from their employer's premises (traveling	1	2020–2020
Noonan v. Illinois Workers' Compensation Comm'n neutral illappct · 2016 2 sentences 2019Although the special concurrence suggests each of these claimants might "arguably" have been held entitled to benefits under a neutral-risk analysis ( infra ¶ 105), there is no indication in any of these cases that evidence existed which would have supported an Adcock -type neutral-risk analysis, such as evidence of the general public's frequency of wiping tables ( Steak 'n Shake ), bending ( Mytnik ), or reaching ( Young and Autumn Accolade ). ¶ 49 The special concurrence further cites our decision in Noonan , 2016 IL App (1st) 152300WC , 408 Ill.Dec. 308 , 65 N.E.3d 530 , as an example of ho 2019In my special concurrence in Noonan , 2016 IL App (1st) 152300WC , ¶ 41, 408 Ill.Dec. 308 , 65 N.E.3d 530 (Holdridge, P.J., specially concurring), I noted that I would decline to follow our prior decisions in Young and Autumn Accolade because each of those cases erroneously failed to apply a neutral risk analysis.	1	2019–2019
Interlake, Inc. v. Industrial Commission green illappct · 1987 1 sentence 2015For example, in Interlake, Inc. v. Industrial Comm’n, 161 Ill.	1	2015–2015

Statutes the citing opinions construe

IL § 820 ILCS 305/1 (15) IL § 820 ILCS 305/2 (4) IL § 820 ILCS 305/19 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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