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As decades rolled past, those in the insurance industry in Missouri became increasingly frustrated by the continuing liberalization in the interpretation and application of the state’s workers’ compensation law. Many in the industry thought the law had evolved to a point where the distinction between a work-related injury and a personal injury, and an occupational disease or a disease of everyday life, had become very blurred.

In 1983, matters took a turn for the worse when the state Supreme Court decided two cases in rapid succession in which the court adopted an interpretation of the law that only required an employee to prove that the injury was “work-related,” even if the relationship was only that the employee injured his or her back while merely bending down to pick up a pencil from the floor at work.

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