In Stockham Pipe Fittings Co. v. Williams, 245 Ala. 570, 18 So. 2d 93 (1943) Williams entered the bathhouse and locker room after his work shift and proceeded to instigate horseplay with another employee. The other employee retaliated; this retaliation ultimately led to an injury that caused Williams's death the following day. In denying compensation benefits to Williams's family, the court noted: "No one else engaged in this 'horseplay' and Williams was the aggressor." The court further found that Williams's death did not arise out of his employment. The court stated, "Under the modern authorities, for an injury resulting from horseplay to be compensable, such horseplay must not be instigated by the injured workman and he must at the time be engaged in the duties of his employment." Stockham Pipe Fittings, 245 Ala. at 573, 18 So. 2d at 95.