## Facts

- George A. Geotakes worked for Great Eastern Food Products, Inc. at its plant.
- During work, he experienced dizziness caused by a personal cardiovascular condition unrelated to his job.
- The dizziness caused an idiopathic fall to a level concrete floor; he struck no intermediate object.
- His head hit the floor, fracturing his skull, and he died weeks later from that injury.
- The only alleged workplace condition contributing to injury was the ordinary hard floor on which he was required to stand and work.
- The Division of Workmen’s Compensation dismissed claims for compensation; the county court and Appellate Division affirmed, relying on precedent denying recovery for idiopathic falls on level floors.
- The New Jersey Supreme Court granted review to reconsider that precedent.

## Issues

1. Whether death resulting from an idiopathic fall onto an ordinary level concrete floor, occurring in the course of employment, constitutes an “injury by accident arising out of” employment under the New Jersey Workmen’s Compensation Act.
2. Whether the “arising out of” requirement demands a special or increased workplace hazard beyond the presence of a level floor when the fall is triggered by a purely personal medical condition.

## Decision

- The New Jersey Supreme Court reversed and held the injury compensable.
- The Court overruled prior New Jersey authority that had treated idiopathic falls onto a level floor as noncompensable.
- The Court adopted a positional-risk approach: if employment required the employee to be at the place of injury and the workplace environment (here, the floor) was the instrumentality of harm, the accident “arose out of” employment despite the idiopathic cause of the fall.

## Legal Principles

- An injury “arises out of” employment when the employment places the worker in the position where the injury occurs and workplace conditions contribute to the harmful result.
- An idiopathic cause initiating a fall does not bar compensation when impact with the employer’s premises is a causal factor in producing the injury.
- A level concrete floor may qualify as a work-related risk because it is part of the employment premises and can be the instrumentality causing injury.
- The statutory “arising out of” requirement is satisfied under a positional-risk theory when the employment-created location and environment account for the injurious contact.

## Conclusion

The court held that an employee’s death from an idiopathic fall was compensable because the employment required him to be on the premises where the concrete floor caused the fatal injury, and it rejected the earlier rule requiring a special workplace hazard beyond the ordinary floor.


George v. Great E. Food Prods., Inc., 44 N.J. 44, 207 A.2d 161 (1965)