## Facts

- Craig F. Haynes was employed by R.B. Rice, Division of Sara Lee.
- On April 19, 1986, Haynes was working at the employer’s plant and was assigned to clean large metal chili tubs in the “chili room.”
- The cleaning job involved directing very hot (about 180°F) water through a high-pressure hose while working alone.
- Haynes was addicted to cocaine and, in the weeks surrounding the incident, had overdosed twice.
- The night before the incident, Haynes injected approximately one and one-half grams of cocaine and drank four to six beers.
- Haynes did not eat dinner or breakfast and did not sleep that night.
- On the morning of the incident, a friend drove Haynes to work because he was in poor condition.
- Coworker James Jamison testified that Haynes kept falling down, could not walk without support, and appeared “out of his mind.”
- About one and one-half to two hours into the workday, Haynes was found lying unconscious on the floor in the chili room with scalding water spraying on his body.
- None of the chili tubs had been rinsed out, and no one witnessed Haynes fall.
- Haynes suffered severe burns and later testified he did not remember what happened.
- Dr. Oxley, a board-certified pathologist, testified that the level of cocaine found in Haynes’s blood after the incident would have made it impossible for him to perform his job duties.
- The Labor and Industrial Relations Commission denied workers’ compensation benefits, finding Haynes’s collapse was idiopathic and related to cocaine use rather than caused by the work.

## Issues

1. Whether Haynes met his burden to prove an accident “arising out of and in the course of” his employment under Missouri workers’ compensation law.
2. Whether the Commission could find Haynes’s collapse was idiopathic and cocaine-related, making the resulting burn injuries noncompensable.
3. Whether the Commission’s findings (including credibility determinations and causation) were supported by competent and substantial evidence on appeal.

## Decision

- The Missouri Court of Appeals (Western District) affirmed the Commission’s denial of benefits.
- The court held that the record supported the Commission’s finding that Haynes’s fall was idiopathic and attributable to his cocaine use.
- Because Haynes failed to prove a work-related cause for the fall, he did not establish that the injury “arose out of” his employment, even though it occurred at work.
- The court deferred to the Commission’s role as factfinder, including its assessment of witness credibility and weight of the medical evidence.

## Legal Principles

- A workers’ compensation claimant bears the burden to prove an accident and that the accident arose out of and occurred in the course of employment.
- “In the course of” generally concerns time, place, and circumstances of employment; “arising out of” requires a causal connection between the injury and a risk related to the employment.
- An idiopathic fall—one caused by a condition personal to the employee—does not satisfy the “arising out of” element unless the employment contributes to the fall or supplies a work-related hazard that provides the required causal connection under Missouri law.
- Severe intoxication or drug impairment may support a finding that a collapse was personal to the employee rather than work-caused.
- Appellate review is limited: if the Commission’s findings are supported by competent and substantial evidence, the reviewing court will not reweigh evidence or second-guess credibility determinations.

## Conclusion

The court affirmed the denial of workers’ compensation because substantial evidence supported the Commission’s finding that Haynes’s collapse was an idiopathic event caused by cocaine impairment, and Haynes therefore failed to prove his burn injuries arose out of a work-related risk rather than a personal condition.


Haynes v. R.B. Rice, Division of Sara Lee, 783 S.W.2d 403 (1989)