SYDNEY A. DURR v. CLARKS MOUNTAIN NURSING CENTER, AMERICARE SYSTEMS INC., and SAFETY NATIONAL CASUALTY COMPANY, SD37212

Sydney Durr, a certified nursing assistant, injured her left knee on March 5, 2015 while refilling a resident's water pitcher in a narrow (≈1-foot) space between the bed and wall; she felt a twisting motion and later required surgery.
Employer had placed the bedside table in that narrow gap to accommodate the resident's wheelchair; the room was dark to avoid waking the resident and the water-ice cart was located in the hallway, requiring quick, repeated trips.
Employer recommended (but the Commission found did not require) closed-toed, non-skid shoes for CNAs; Durr wore those shoes at work but not at home.
The ALJ credited Durr’s testimony, found an identifiable workplace accident, and concluded the injury arose from employment conditions (narrow space + recommended non-skid shoes + work pace) and was the prevailing factor causing her injury.
The Labor and Industrial Relations Commission rejected the ALJ’s award, concluding the risk (twisting/pivoting) was one to which Durr would have been equally exposed in normal nonemployment life and that the shoes were only recommended.
The Court of Appeals reversed the Commission on the central causation issue, adopting the ALJ’s factual findings and remanding for entry of the ALJ award; a dissent would have affirmed the Commission.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the knee injury "arose out of" employment (i.e., risk source unique to work)	The injury resulted from particularized workplace conditions (confined 1-foot gap, employer-placed furniture, expedited duty to refill pitchers, and wearing non-skid shoes at work) so the risk was unique to employment	The twisting/pivoting risk was ordinary and equally present in normal nonemployment life; no causal connection to specialized work conditions	Reversed Commission; court adopted ALJ finding that the injury arose out of employment and remanded for entry of award in favor of Durr
Whether closed-toed, non-skid shoes were required (affecting whether shoes were an employment-related risk source)	Durr: shoes were required as a condition of employment	Commission/Employer: shoes were recommended but not required; record inconclusive	Not reached by the court (Point I dispositive); Commission's finding on requirement was not addressed on appeal

Annayeva v. SAB of the TSD of the City of St. Louis, 597 S.W.3d 196 (Mo. banc 2020) (requires causal connection between injury and work activity under § 287.020.3)
Johme v. St. John's Mercy Healthcare, 366 S.W.3d 504 (Mo. banc 2012) (no causal connection when risk was equally present in nonemployment life)
Miller v. Missouri Highway and Transp. Comm'n, 287 S.W.3d 671 (Mo. banc 2009) (injury not compensable where nothing about the work caused the injury)
Schoen v. Mid-Missouri Mental Health Center, 597 S.W.3d 657 (Mo. banc 2020) (no causal connection when injury resulted from an intervening, non-work-related event)
Boothe v. DISH Network, Inc., 637 S.W.3d 45 (Mo. banc 2021) (claimant must show risk source related to employment and not equally present in nonemployment life)