## Facts

- William Gerald Coomes, age 48, worked for Robertson Lumber Company as a truck driver and lumber-yard worker.
- On September 10, 1964, Coomes returned from lunch and resumed work unloading two-by-fours from a truck in the lumber yard.
- A company salesman saw Coomes shortly after his return and testified Coomes appeared normal.
- Less than an hour later, the salesman found Coomes in the yard after an apparent fall: Coomes was staggering, had a bloody forehead, and appeared dazed.
- No one witnessed the fall, and the record did not establish what Coomes struck or the immediate mechanism of injury.
- Coomes’s wife testified he seemed fine at lunch; after she brought him home, he soon stiffened and convulsed, prompting an ambulance call.
- Hospital examination revealed a severe skull fracture.
- The record contained no evidence that the fall resulted from an idiopathic or purely personal condition.

## Issues

1. Whether an unexplained, unwitnessed fall occurring during work on the employer’s premises, without evidence of idiopathic cause, permits (or requires) an inference that the injury “arose out of” employment for workers’ compensation purposes.
2. Whether the Workmen’s Compensation Board could deny benefits for lack of a proven causal mechanism when the injury occurred in the course of employment and no non-work-related cause was shown.

## Decision

- The Court of Appeals of Kentucky reversed the circuit court’s judgment affirming the Board’s denial of compensation and remanded.
- The court held that, on these facts, Coomes’s injury was compensable as a matter of law.
- The court rejected the Board’s approach of requiring specific proof of how the fall occurred or what caused it, given the accident was unwitnessed and unexplained.
- In the absence of evidence of an idiopathic or personal cause, the circumstances supported treating the injury as arising out of the employment.

## Legal Principles

- A workers’ compensation claimant must show an injury occurred “in the course of” and “arose out of” employment.
- When an employee sustains an unexplained fall in the course of employment and there is no evidence of an idiopathic cause, a rebuttable presumption (or inference) arises that the injury also “arose out of” the employment.
- In unexplained-fall cases, circumstantial proof that the accident occurred at work while performing assigned duties may satisfy the “arising out of” element absent contrary evidence.
- A compensation tribunal may not deny benefits solely because the claimant cannot prove the precise mechanism of an unwitnessed workplace fall when the record lacks evidence of a non-work-related cause.

## Conclusion

Because Coomes was injured at work while performing assigned duties and the fall was unexplained with no evidence of an idiopathic cause, the court held the injury presumptively arose out of employment, reversed the denial of benefits, and remanded for further proceedings consistent with that rule.


Coomes v. Robertson Lumber Co., 427 S.W.2d 809 (Ky. Ct. App. 1968)