Falling Down the Stairs at Work in Virginia

In Southside Virginia Training Ctr. v. Shell, 20 Va. App. 199, 203, 455 S.E.2d 761, 763 (1995), the employee injured herself when she fell down stairs at work and was awarded benefits. She testified there was nothing unusual about the steps, they were well lit, and did not contain any debris. The Court reversed the commission's finding that the fall arose out of the employment because the steps were not defective and there was no evidence the fall resulted from a particular risk of the employment such as being hurried or distracted. In Shell, the Court reversed an award on the ground that "nothing in the record shows an abnormality in either the angle of the rise or the dimensions of the tread or carriage, a handrail is attached," and the claimant testified "the area was well lit, . . . no foreign substance on the steps caused her fall, and there was nothing unusual about the steps." Shell, 20 Va. App. at 201-02, 455 S.E.2d at 762;