## Facts

- Arthur L. Rumple worked for Hill-Luthy Co. delivering and installing water tanks at customers’ homes.
- On July 31, 1947, after finishing work at a farm customer’s home, Rumple returned to the employer’s truck to drive to his next stop.
- While seated in the truck cab and preparing to depart, Rumple struck a match to light a cigarette; the match head flew off and struck his left eye.
- The injury resulted in severe damage and eventual loss of the eye.
- Rumple sought workers’ compensation benefits, claiming the injury arose out of and in the course of employment.

## Issues

1. Whether an eye injury caused by a match head while the employee lit a cigarette in the employer’s truck between service calls arose out of and in the course of employment under the Illinois Workmen’s Compensation Act.
2. Whether the employee’s momentary smoking-related act constituted a personal deviation that severed the employment connection.
3. What deference courts owe to the Industrial Commission’s findings on compensability.

## Decision

- The Illinois Supreme Court reversed the circuit court and reinstated the Industrial Commission’s award.
- The court held the accident occurred in the course of employment because the employee was in the employer’s truck during the workday, between assigned calls, preparing to proceed to the next job.
- The court held the injury arose out of employment because lighting a cigarette was treated as a foreseeable personal-comfort act incidental to the employment under the circumstances.
- The court found no abandonment of employment or engagement in an activity wholly foreign to work.
- The court concluded the circuit court improperly displaced the Commission’s supported factual determination.

## Legal Principles

- An injury is compensable when it both occurs in the course of employment (time, place, and circumstances of work) and arises out of employment (causal connection to a risk connected with or incidental to the work).
- Under the personal-comfort doctrine, brief acts reasonably expected during work (e.g., eating, drinking, warming oneself, smoking) generally remain within the course of employment, and the incidental risks of those acts may be treated as risks of employment when the employee is where the job requires.
- A minor, momentary personal act does not defeat compensability absent a substantial deviation or abandonment of employment duties.
- Whether an accident arises out of and in the course of employment is commonly a fact question for the Industrial Commission; reviewing courts should not disturb the Commission’s findings unless they are manifestly against the weight of the evidence.

## Conclusion

The court held that an employee’s eye injury from lighting a cigarette while seated in the employer’s truck between work calls was sustained in the course of and arising out of employment, and it reinstated the Industrial Commission’s compensation award.


Hill-Luthy Co. v. Industrial Comm’n, 411 Ill. 201, 103 N.E.2d 605 (Ill. 1952)