Industrial Commission v. Havens

specially concurring:

What should be the abiding rule for the establishment of a prima facie claim in a workmen’s compensation case where the evidence as to the causal connection between the employment and the death of the employee is wholly circumstantial? The majority opinion contains the answer, but I think we should attempt a more explicit statement of the applicable principles than appears in such opinion. This concurring opinion is an effort at achieving such statement.

Circumstantial evidence is sufficient to make out a prima facie case, and it may be based upon the reasonable inferences…