In Graham v La-Z-Boy Chair Company, 117 S.W.3d 182, (Mo. App. S.D. 2003), employer appealed a determination that employee was entitled to workers’ compensation benefits. Employee was injured while golfing at tournament sponsored by employer’s client. The Court of Appeals applied the “mutual benefits doctrine,” and determined that employee was not injured while participating in a “voluntary recreational activity.”
In Blades v Commercial Transport, Inc., 30 S.W.3d. 827, (Mo.banc. 2000), a worker was injured when he fell on the sidewalk entering the union hall to testify in an arbitration proceeding under the collective bargaining contract. Under the Mutual Benefit Doctrine, the employee was not entitled to compensation as the employer obtained some benefit from the settlement of disputes under the contract by arbitration. The Mutual Benefit Doctrine states that an injury suffered by an employee is usually compensable while performing an act for the mutual benefit of the employer and the employee, for when some advantage, however slight, the employer obtains from the employee’s conduct, his act cannot be regarded as purely personal and wholly unrelated to the employment. Accordingly, an injury resulting from such an act arises out of and in the course of employment. The Court found any benefit from claimant testifying against the Employer was too attenuated.