Marion Corr. Treatment Ctr. v. Henderson

In Marion Corr. Treatment Ctr. v. Henderson, 20 Va. App. 477, 458 S.E.2d 301 (1995), the Court affirmed a finding that the employee's injury arose out of his employment as a prison guard. The employee fell down steps while looking at a guard tower. His duties required him to receive an acknowledgement signal from the tower guards. The employee had to observe the towers rather than the steps he was traversing. "The way in which he performed this aspect of his job increased his risk of falling on this occasion and directly contributed to cause his fall and injury." Id. at 480-81, 458 S.E.2d at 303.