AV Automotive and VADA Group Self-Insurance Association v. Yahia Mohammed, 1432164

Mohammed, an employee at AV Automotive, slipped and fell on the showroom floor on July 13, 2015, fracturing his right humerus.
The Virginia Workers’ Compensation Commission awarded Mohammed medical benefits and temporary total disability from July 14, 2015 to October 29, 2015.
AV appealed, arguing Mohammed failed to prove his injury "arose out of" employment and pointing to gaps in contemporaneous statements to medical personnel and an adjuster.
The Commission relied on Mohammed’s hearing testimony and surveillance video showing him slip, concluding the floor’s slipperiness caused the fall.
The Court of Appeals reviewed whether the injury "arose out of" employment under the actual risk test and treated the Commission’s causation finding as a factual determination entitled to deference.
The Court affirmed the Commission, holding the slippery showroom floor was a work-specific hazard and thus the injury arose out of employment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mohammed’s injury "arose out of" his employment	Mohammed: fall caused by slippery showroom floor at work; surveillance and testimony support causation	AV: no contemporaneous medical or adjuster statements saying floor was slippery; alternative causes (e.g., slippery shoes) possible	Held: Injury arose out of employment; Commission’s finding of a slippery floor as cause is supported by credible evidence and binding

Town & Country Hosp., LP v. Davis, 64 Va. App. 658, 770 S.E.2d 790 (discussing appellate view of Commission evidence)
Dominion Coal Corp. v. Bowman, 53 Va. App. 367, 672 S.E.2d 122 (Commission’s factual causation findings are binding)
TBC Corp. v. Stephens, 49 Va. App. 650, 644 S.E.2d 84 (workers’ compensation requires injury arising out of and in the course of employment)
Bassett-Walker, Inc. v. Wyatt, 26 Va. App. 87, 493 S.E.2d 384 (separate proof required for "arising out of" and "in the course of")
Blaustein v. Mitre Corp., 36 Va. App. 344, 550 S.E.2d 336 (arising out of is a mixed question reviewed de novo)
County of Chesterfield v. Johnson, 237 Va. 180, 376 S.E.2d 73 (definition of "arising out of")
Vint v. Alleghany Regional Hosp., 32 Va. App. 60, 526 S.E.2d 295 (use of the actual risk test)
Marketing Profiles v. Hill, 17 Va. App. 431, 437 S.E.2d 727 (quoting actual risk test language)
Bradshaw v. Aronovitch, 170 Va. 329, 196 S.E. 684 (actual risk / causation framework)
Dollar Tree Stores, Inc. v. Wilson, 64 Va. App. 103, 765 S.E.2d 151 (discussion of actual risk test application)