Hamilton . SAIF Corportaion

An employer's requirement that an employee stand on a hard floor does not significantly increase the risk of injury, and, therefore, by itself, cannot prove a causal nexus between employment conditions and injuries resulting from falling down.

Hamilton sought review of a decision by the Workers' Compensation Board (Board) that her injury was not compensable. Hamilton was injured when she fell from the standing position onto the brick floor of her workspace. Hamilton argued that, (1) contrary to Board's finding, the "mixed risk" doctrine does apply to idiopathic (personal), ground-level falls, and (2) Board should have considered her employer's requirement that she stand on a hard brick floor during work as contributing to her injury. The Court of Appeals disagreed with Hamilton, holding that the Board correctly determined that no work-related conditions caused or contributed to her fall. The Court further held that, as a matter of law, standing on a hard floor did not significantly increase the risk of injury. Hamilton, therefore, failed to prove a causal relationship between her employment and her injury. Affirmed.