Graybeal v. Bd. of Sup'rs of Montgomery Cty
In Graybeal v. Bd. of Sup'rs of Montgomery Cty. (1975) 216 Va. 77 216 S.E.2d 52, 54 compensable injury was found for a prosecutor who was severely injured as a result of a bomb being placed at his home by someone he had prosecuted for a crime years earlier.
The Virginia court's treatment is instructive. "Considering, then, that in the context of the present case 'arising' means 'originating,' we believe the claimants nighttime injury from the exploding bomb placed on the top of his family car no less arose in the course of his employment than if he had been shot by his revenge-seeking assailant in the courtroom immediately following the murder trial, or if he had been injured by a bomb triggered to explode in his office upon his return from the courtroom. The difference is in degree only and not in substance. In the realities of the present case, the course from prosecution to desire-for-revenge to injury was unbroken, constituting a single work-connected incident." ( Graybeal, supra , 216 S.E.2d at p. 54.)