## Facts

- Thelma J. Grimes worked as a media technician for the Leon County School Board.
- Grimes had residual effects of childhood polio and used a full-length right-leg brace that required manual locking when she stood.
- While rising from her desk to reach a file at work, Grimes locked the brace as usual, but it gave way; she fell on a carpeted floor and fractured her left ankle.
- Evidence indicated the brace had given way previously at home.
- Grimes sought workers’ compensation benefits.
- The deputy commissioner denied benefits, finding the fall stemmed from a personal, idiopathic risk unrelated to work and involved no work-related exertion or hazard beyond ordinary nonemployment life.

## Issues

1. Whether an injury from a fall attributable to an idiopathic, personal condition “arises out of” employment under Florida workers’ compensation law without proof that workplace conditions created an increased risk or hazard.
2. Whether the appellate court could reverse the deputy commissioner’s compensability determination where the deputy’s fact findings were supported by competent substantial evidence.

## Decision

- The Florida Supreme Court answered the certified question in the negative.
- The Court quashed the First District Court of Appeal’s decision and reinstated the deputy commissioner’s denial of benefits.
- The Court held the record supported the deputy commissioner’s finding that the employment conditions did not contribute to the injury.

## Legal Principles

- An injury “arises out of” employment only if there is a causal connection between the employment and the injury, shown by a work-related increased hazard compared with risks in the employee’s nonemployment life.
- Injuries from idiopathic falls are not compensable unless the employment contributes to the risk by creating an increased hazard that materially adds to the injury risk.
- Mere presence on the employer’s premises does not make an injury compensable; workers’ compensation does not treat the employer as an insurer for all on-premises injuries.
- Appellate courts must respect a deputy commissioner’s fact findings when supported by competent substantial evidence, and may not substitute their view of compensability on a supported record.
- Any broad shift to a positional-risk or actual-risk approach is a policy choice for the legislature, not the judiciary.

## Conclusion

Because Grimes’s fall was caused by a personal idiopathic condition and the workplace (including the carpeted floor) did not create an increased hazard contributing to the injury, the injury did not “arise out of” employment and workers’ compensation benefits were properly denied.


Leon Cnty. Sch. Bd. v. Grimes, 548 So. 2d 205 (Fla. 1989)