Saunders v. Industrial Commission

As the majority opinion correctly points out, Illinois has never enacted a statutory defense of safety rule violation. Thus, in determining whether an injury arose out of claimant’s employment, the question is whether claimant overstepped the boundaries defining the work to be done (not arising out of) or whether the violation related to the method of accomplishing the work to be done (arising out of). See 2 A. Larson & L. Larson, Larson’s Workers’ Compensation Law § 31.00, at 6 — 10 (1997).

Claimant was within the plant on his way to the break room for a scheduled 10-minute break. As such, he…