In Otte v Langley’s Lawn Care, Inc., 66 S.W.3d 64 (Mo.App. E.D. 2001), claimant, who was authorized to ride to and from work with his brother in an employer provided truck, sustained injury on way home, held compensable under “multiple benefit doctrine”.

In State ex rel Chang v Ely, 26 S.W.3d 214 (Mo.App. 2000) (ALJ J. Smart). Employee files suit against home business, court finds claimant was an employee and not a business invitee and that claimant was about to commence her normal workday when accident occurred.

Accident During Travel to and from Authorized Medical Treatment

In Bear v Anson Implement Co., 976 S.W.2d 533 (Mo.App. E.D. 1998), the employee was hurt on his way home from treatment authorized by the employer in an auto accident. The injuries were sufficiently unrelated to the primary accident, and therefore not compensable. The Court cited Snowbarger v MFA Cent. Corp., 349 S.W.2d 224 (Mo. En Banc. 1961) to the effect that recovery for secondary injuries is limited to those “causally connected to a primary injury.” There has to be some connection between the primary injury which by its nature contributed to the subsequent injury in some way other than merely the occasion for harm which is totally unrelated to the source.