client is you know from reading of the facts works for the teamsters in his travels and travels from various venues to set up and tear down whatever display is really doesn't work for the teamsters well you're right he doesn't work  that location because it was at the direction of being employed every morning and is there a distinction yes but you can legitimately and logically argue that he was there at the premises or the employer's promises are considered right of the course of the climb aboard the employee slips and falls at a point off the employer's premises which is clearly it was an avid premises when he was injured wrecker and then he needs to fall under other exceptions right we would he would be the man who obtained the order from the bosses there to bring in so many teamsters and he testified that when anybody is assigned to work there they are to come in a certain door by his office where his desk was but they had to park nowhere near the donald the stephen center but in the william street parking garage two other late witnesses coworkers of my client testified to the same thing and in fact they testified that they recently were given certain kinds of passes to be used as opposed to the union card so the only reason my client was damp location at the time he fell was because he had parked his car where he was directed by the powers that be at the down of the stevenson or was walking from the parking lot with his work equipment and his lunch and he slipped on black ice and f so the question is this case covered is it compensable using the logic obama retold or do we say it's excluded because of reid and has versus the industrial commission those employee embalmer ito was required to go through the alley to get to the rear door to enter the employer's premises well if you did in this case that there would be employer dictate the route or what sidewalk or which entrance the employee claimed it was supposed to enter that there's only one there so there was testimony there's only one way to get from the william street garage to the down will be steven center and the doorway where he had to enter that was never an issue in terms of deviation from the route w by using any specific route directed back to respond that there were no other things going and what was there your honor first of all if i may in a certain sense challenge your reading of bom bom rito didn't turn on the question that she was going through korea or he was going through crater filled else i believe that the logic in the rule of law is enunciated in that case by the supreme court stood for the proposition that whenever an individual is directed by their employer to follow a certain em into their workplace into park at a certain designated area and if it is a result of traversing debt route the most reasonable move if you will they come across something that is a greater risk to them because they're there because of the nature of their directive of the employer so it's an absolute that you're saying that any time somebody goes to a gap site required by employer regardless of what happens between the garage and the place of work public sidewalk a cross grant park and he's directed park in the millennium part of the russian underground and he has to ammend himself to the i b m building on a regular street and he chooses which way to go whether it's across the grass or a walk away or gets a segway or whatever that would be a different situation because of the freedom of choice here there is only one route to get directly from the parking garage to the down  sun it's not much he's got a multiplicity in fact when asked directly whether or not there was an alternative route he said there's a pen way that you could take but it was closed at this hour the other two witnesses testified that in every instance when they went to work there they were directed to park in the william street garage the man who assigns the jap the formula lead me and he testified that yes it is the policy of the owners of battle the stephen center that they parked in the william street garage and they get in there for free they don't have to pay because they show their teamsters card and then the other two witnesses testify that they're given identifications ls goes to their supposed to park at the way into the garage but getting from the frankly well but but and so the bottom line it helps to say didn't have a choice here i had to go through that route even though there could be other routes and bomber i had to go through that route and that was the risk of injury that i had it but the issue is this is an individual in the course of his employment when directed by the employer to park in a particular location and then traverse the most direct route from the parking garage with the most direct route because that assumes that there is some indirect route there is he said are you disputing the fact that the claimant himself testified that looking at now there is two brady situation whatsoever this is an instrument tell of the that's a stranger to the equation this isn't a situation where like in grade the guys doing sit news drafting table writing drawing lines and a truck crosses the centerline on route fifty three goes down thirty eight feet and lands into the side of the building disempowering we got here what we have is we have a boss if you will only most generic sense says by ah you park over there everybody admits that's where they that's where they're required to park your park over there you don't have to pay to get in for free because you're working here when you're park your car then you can walk back the block that joins these two places the william street the rye and  most recent one but for example in campbell sixty six a very old case where the guy's driving his tractor trailer through kansas or nebraska along comes a tornado and knocks him over the response to that case argue positional risk in that black eyes and enough air that he was there because the employer said you must park over there then creates a risk greater to him than the general public maybe he wasn't there a good hour maybe even if i was out of public advocate his to be your position nothing else matters well in this instance that is true not because in mind you this guy is a squeeze i traveling employee the place of business for the assignment for his jobs is at mccormick place to power beat the need to go down to mccormick place at an early hour in the morning and then go back to the family stevens location the teamster guy calls him up at four thirty or five o'clock in the evening and says tomorrow bob you go to the steven center ok great he drives his car there he parks in the designated parking spot he gets in for free because they give him the sick commendation because he's working at the battle of the steven center he gets out of his car he's got his tools and is gloves and so on he walks to the most direct route parallel to the street directly before going to the bottom of the stevens he encounters this black ice falls and has a spiral fracture the question is why was he there or was he there for we see there for same parking lot of course they've got to pay they have to get a time card that says how long you've parked in the new pay the freight but the fact of the matter is he's we are he is when he falls because of the direction of his employer we don't know what benefit this employer gains from him having to park in that lot but the fact of them in a real is all of the testimony is he's required to park in that lot and as a consequence well then it and then in the absence of any traveling employee case we would say that anybody who's on a public way or in any other fashion is subject to the same or says general public and unless you can get safely to your workplace you're not not employed i mean you're not a doesn't where he fail was any inherent risk because of the black ice and he was exposed to that risk because he was following the mandate of the employer by parking in the william street garage and then taking that route that was directly to the down the steep hill had they never told him the park there he had if he had a choice is to park wherever he wanted i'm not here why was he on the driveway that morning going to the down the stephen center because he was told to park in that garage and then come in to work and he had to traverse they just like a marina on the other side thank you risks or hazards encountered by the claimant as a result of the response order to enter through the rear door own must be deemed to arise out of for employment moreover the claimants obedience to that order operates to place the claimant sconce when injuries within the scope of and the respondent you're in has created a situation whereby the claimant was forced to dodge traffic and debris in order to gain admission to a place of work the responding cannot seriously expect to disclaim responsibility for the claimants injuries simply because the claimant was unable to traverse this obstacle course successfully i would submit to you this is a very different case where in rosemont i'll get back to travelling employer the quads i travel employs mr alexia suggested but we're in rosemont the man is directed to park in a public lot where the teamsters do have access and aren't allowed here he's able to traverse across river road but before he gets three falls on a side general public the restaurant patrons this coverage we no longer have an arising out of it it is unless you take the position of positional risk where he's merely there because he has to work then we don't have to have any greater exposure for the employer or for the employee commission cases for example tell me they actually clear away the public walk responded to us and it was noted that they'd clear away ice and snow just before the petitioner had the employee and walk around that area and it had become a matter of  same employer in this case roseman exposition services hired this man out of the hall and he was told to show up to one yes they're not he's not in the manner of doing his job very different places i don't believe that the traveling exactly right roger it's no different than any other employee travelling to their place of business and it's remains the same so in that case we've got a situation where again arising out of disappears merely because the person has to show up  at a designated place and time as soon as they park in council's argument they are benefiting the employer because they're showing up to work and they are underneath the workers compensation that we can have a compensable claim by falling on a sidewalk that was offering the same benefits and exposures to the general public as to this employee argued and one is a case where the employee was required to traverse a bad argument which was required by the employer multiple times in order to get her materials and it was noted by the cour that the employer also paid to maintain that are in this case we don't have that situation to enter the stevens convention center and any of those doors it's uncontroverted in the evidence could be used to enter to check in with the employer in order to be given the jobs but is there only one route to the multiple doors the employee off premises is not entitled to workers compensation benefits when our general when exposed to the same risks and hazards at the trial of the cases that counsel cites don't thank you ron or one way as he has much field health care which will health care center versus the industrial commission dischord two thousand and four and in their instance claim was walking from the parking lot to the building when she tripped over an uneven part of the side in fighting the accident compensable the court highlighted the significance of the hazardous condition in an even sidewalk here black eyes whoever lives feel wasn't it the injury that occurred on the employer premises no it was not you know the case is not merely involved the risks inherent in walking on a sidewalk which confront all members of the public when as in this case in injury to an employee takes place in the area which is ice not easily distinguishable the hazard becomes part of the employee special his or risks encountered as a result of using a usual answer access route satisfy the rousing a right out of requirement of the