In Bear v Anson Implement Co., 976 S.W.2d 533 (Mo.App. E.D. 1998), the employee was hurt in an auto accident on his way home from treatment authorized by the employer. The injuries were held to be unrelated to the primary accident, not compensable. The appellate court cited Snowbarger v MFA Cent. Coop. ,349 S.W.2d 224 (Mo.banc. 1961), where the proposition that only secondary injuries which are casually connected to a primary compensable injury are themselves also compensable. The primary injury must contribute to the subsequent injury in some positive way other than merely being the occasion for it.
(The case is yet to come where the claimant is on her or his way from the employer’s premises to the authorized treater. These issues will then be whether the employee has “clocked out”, is still technically on the payroll, or, once he leaves the employer’s premises, is absolutely on her or his own.)
In Hicks v May Dept. Stores, 2-2-01 (LIRC) (ALJ Denigan) Claimant alleges she left work early to go doctor’s office from earlier parking lot accident, court found claimant failed to prove timely notice.