## Facts

- Terry Crain worked for Technical Tape Corporation on a 3:00 p.m. to 11:00 p.m. shift.
- Near the end of the shift, Crain was instructed to clean residue from a large, mostly enclosed glue churn with a small top opening.
- The glue mixture included toluene, a solvent associated at the workplace with intoxication-like effects in workers cleaning the churn.
- Crain worked inside the churn for over 30 minutes and exited around 10:45 p.m.
- Upon exiting, Crain reported burning in his feet and legs, nausea, dizziness, and feeling ill; his father (a co-employee) observed red streaks on Crain’s neck.
- Shortly after leaving the plant, Crain drove erratically for about five miles, ran a stop sign, and collided with another vehicle.
- Crain sustained serious injuries, including disfigurement of his left ear, a fractured skull, and partial loss of use of his right foot.
- Crain sought workers’ compensation benefits, asserting the toluene exposure caused impairment that led to the accident.
- An arbitrator awarded benefits; the Industrial Commission affirmed; the circuit court affirmed; the employer appealed.

## Issues

1. Whether injuries from an off-premises automobile accident after work “arose out of and in the course of” employment when the employee allegedly became impaired from workplace toluene exposure shortly before leaving.
2. Whether the Industrial Commission’s causation finding and award were against the manifest weight of the evidence.

## Decision

- The Illinois Supreme Court affirmed the circuit court’s judgment upholding the Industrial Commission’s award.
- The Court held the evidence supported a reasonable inference that Crain’s workplace exposure to toluene fumes caused an impaired condition that contributed to the accident.
- The Court concluded the Commission’s finding of causal connection was not against the manifest weight of the evidence.

## Legal Principles

- An injury occurring off the employer’s premises after the work shift may be compensable when a work-created condition (including chemical-fume impairment) is a causal factor leading to the later injury.
- The Industrial Commission is the primary fact-finder on causation in workers’ compensation cases; its findings will be upheld unless they are against the manifest weight of the evidence.
- Circumstantial evidence and reasonable inferences (including timing, observed symptoms, and known effects of workplace substances) may establish the causal link between employment and injury.

## Conclusion

The court sustained a workers’ compensation award for an employee injured in a post-shift, off-premises car crash because the Commission could reasonably find that the employee’s work-assigned exposure to toluene in a confined glue churn caused impairment that led directly to the accident, and that finding was not contrary to the manifest weight of the evidence.


Technical Tape Corp. v. Indus. Comm’n, 58 Ill. 2d 226, 317 N.E.2d 515 (Ill. 1974)