American International Vacations v. MacBride

In American International Vacations v. MacBride, 99 Nev. 324, 326, 661 P.2d 1301, 1302 (1983), an employee's knee "'gave way' two or three inches, causing a twisting motion and pain and discomfort in his lower back." The employee continued with his duties, but was admitted to the emergency room the next morning for back pain. He eventually had to undergo surgery on his back for a rupture of an intervertebral disc caused by the twisting incident at work. The Court determined that the incident satisfied the "suddenly and violently" requirement of an accident. Id. at 327, 661 P.2d at 1303. In doing so, this court recognized that "other jurisdictions . . . have construed similar statutory requirements that compensable accidents occur 'violently' as properly descriptive of any cause efficient in producing a harmful result." Id.