Metropolitan Water Reclamation District v. Illinois Workers' Compensation Commission, 407 Ill. App. 3d 1010

Lindquist was a 61-year-old accounting clerk for the District for 13 years performing clerical duties and deposits for the District.
On November 9, 2005, she fell while walking to the bank to deposit checks, stumbling on a six-inch dip in a driveway that intersected a public sidewalk.
She sustained bilateral distal radius fractures, treated with casts and subsequent external-fixation, and later returned to work March 6, 2006.
An arbitration court found the injury occurred during a required work task but that it did not arise out of employment because the risk was not greater than that faced by the public.
The Commission reversed, concluding the injury arose out of employment due to the street risk and frequency of exposure; the circuit court reversed the Commission, and the District challenged.
The appellate court reinstates the Commission’s decision awarding benefits, reversing the circuit court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the injury arise out of employment?	Lindquist argues the accident arose in the course of employment due to a required task and street exposure.	District contends the risk was neutral and not greater than the general public’s risk.	Yes; injury arose out of employment; Commission decision reinstated.
Does the street risk doctrine apply to establish increased exposure?	Lindquist was required to traverse streets for deposits, increasing exposure to street hazards.	District argues no greater exposure or applicable presumption.	Yes; claimant exposed to street hazards to a greater degree; benefits awarded.

Caterpillar Tractor Co. v. Industrial Comm'n, 129 Ill.2d 52 (Illinois 1989) (arising out of employment requires causal connection)
Potenzo v. Illinois Workers' Compensation Comm'n, 378 Ill.App.3d 113 (Ill. App.3d 2007) (street vs neutral risk; quantitative/qualitative increase)
Illinois Institute of Technology Research Institute v. Industrial Comm'n, 314 Ill.App.3d 149 (Ill. App. 2000) (neutral risks; increased risk standard)
City of Chicago v. Industrial Comm'n, 389 Ill. 592 (Illinois 1945) (street risk doctrine; presumption of greater exposure)
C.A. Dunham Co. v. Industrial Comm'n, 16 Ill.2d 102 (Illinois 1959) (street hazard concept; travel on streets as employment risk)
Durand v. Industrial Comm'n, 224 Ill.2d 53 (Illinois 2006) (manifest weight standard in review of Commission findings)
Illinois Consolidated Telephone Co. v. Industrial Comm'n, 314 Ill.App.3d 347 (Ill. App.3d 2000) (neutral risks; frequency of exposure analysis)