This Note examines the broadened application of Missouri’s workers’ compensation statute under Smith v. District II A & B, in which the Missouri Court of Appeals awarded workers’ compensation benefits to a worker injured when he drove from a work function while intoxicated. By awarding workers’ compensation benefits to cover illegal conduct such as illegally driving while intoxicated, Missouri courts are violating legislative intent, violating the historical purpose of workers’ compensation, and potentially hurting the society the legislature sought to unburden when it created a compensation scheme for injured workers.

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