Circle K Store No. 1131 v. Industrial Commission

In Circle K Store No. 1131 v. Industrial Commission, 165 Ariz. 91, 796 P.2d 893 (1990), the supreme court held that an unexplained injury occurring within the scope of employment is presumptively compensable. In Circle K, the claimant fell for an unexplained reason while throwing out store trash in Circle K's dumpster on her way home. After determining that an unexplained fall is a neutral injury, our supreme court held that, "in the case of a neutral injury, the positional-risk doctrine applies." Id. at 96, 796 P.2d at 898. Under the positional risk doctrine, a court presumes that an injury arose out of the employment "'if it would not have occurred but for the fact that the conditions and obligations of the employment placed claimant in the position where he was injured.'" Id.