On the other hand, random or even planned assaults or murders that happen in the workplace are often not covered. In one notable case, Carnes v. Tremco Mfg. Co., an employee was murdered inside the workplace by one of her co-workers. However, the reason for the murder was that the two had broken off an extra-marital affair. After that, the co-worker had stalked the worker both inside and outside the workplace. The Kentucky Supreme Court concluded that the workplace and nature of their work neither “exacerbated” nor “precipitated” the murder, and thus denied comp benefits to the widower.

The court also quoted a previous decision: “Where an employee is assaulted and injury is inflicted upon him through personal animosity arising over some cause wholly disconnected with the employer’s business, no recovery can be had even though he is assaulted when in the discharge of his duties.”