Lieutenant’s Slip-And-Fall Injury In Parking Lot Merits Award

Case name: Behnke v. Bannockburn, Village of /Police Dept., 12 ILWCLB 70 (Ill.Ind.Comm. 2004).

Ruling: The Commission affirmed the arbitrator’s decision awarding benefits to a police lieutenant who suffered a slip-and-fall injury in a parking lot in front of a food store. The lieutenant’s job description required that he make security checks in the early morning hours regardless of the weather conditions.

What it means: A police officer’s injuries sustained in a public store parking lot are compensable where he is performing tasks specifically designated within his job description.

Summary: An on-duty police lieutenant parked in a lot in front of a food store shortly after 6a.m. His designated patrol duties included security checks of village business at opening and closing time. As he crossed the parking lot in freezing rain to enter the store, he slipped and fell on black ice. The arbitrator awarded benefits, reasoning that the claimant was performing tasks specifically designated within his job description- crime prevention- in weather conditions which his job description mandated he work within. Unlike the general public, which could choose not to go out in freezing rain at 6 a.m., the claimant’s job duties and job description required him to do so. As such, the claimant’s injuries arouse of and in the course of his employment. Upon review, the Commission affirmed and adopted the decision of the arbitrator.

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Donald W. Fohrman & Associates, Ltd.