PYA/Monarch and Reliance Ins. Co. v. Harris

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• compensability of unexplained fall results only from application of positional risk doctrine, which has been expressly rejected in Virginia in non-death cases in favor of actual risk doctrine
• “[I]n an unexplained fall case . . . , a claimant must prove by a preponderance of the evidence that the fall ‘arose out of’ the employment by establishing a causal connection between . . . her employment and the fall.”
• “The concepts ‘arising out of and ‘in the course of employment are not synonymous and both conditions must be proved before compensation will be awarded.” (quoting Marketing Profiles, Inc. v. Hill, 17 Va.App. 431, 433, 437 S.E.2d 727, 729 (1993) (en banc))

Source: CourtListener parenthetical corpus (CC0).