The Illinois Supreme Court has ruled that an employee's injuries from common everyday activities, such as bending, kneeling, and reaching, are compensable under the Illinois Workers' Compensation Act if the employee might reasonably be expected to perform those actions incidental to their assigned duties. The case is McAllister v. Illinois Workers' Comp. Commission, 2020 IL 124848.

Kevin McAllister, the claimant, injured his right knee while he was working as a sous-chef at North Pond restaurant in Illinois. His job required him to check in orders, arrange the walk-in cooler, and preparing and cooking food. On the date of the accident, McAllister was setting his station for the evening shift when a co-worker mentioned that he had misplaced a pan of carrots in the walk-in. In looking for the missing carrots, that could have been located on the bottom shelf, McAllister knelt down on the floor of the walk-in. When standing up from the kneeling position, McAllister felt his knee pop, the knee locked up and he could not straighten it. He discussed the injury with his boss, the general manager drove him to the hospital. He did not receive workers' compensation benefits while he was off work after the injury from August 7, 2014, until he was released to work on September 15, 2014.

The arbitrator awarded workers' compensation benefits to McAllister, finding that looking for misplaced carrots in the walk-in cooler was an act that the employer could reasonably expect a sous-chef to perform in order to fulfill his duties, and accordingly the knee injury "arose out of" and occurred in the course of employment and thus is covered under Workers' Compensation Act, 820 ILCS 305/1 et seq. (2014).