early 20th century, largely because the various defenses available to employers in tort suits left employees injured on the job grossly undercompensated. This system has been described as “a form of strict liability requiring employers, regardless of fault, to compensate employees for injuries arising out of and in the course of employment.”7 The basic test of workers’ compensation liability is simply whether there is a connection between work activities and the injury; “liability is imposed as an incident of the employment relationship, a cost to be borne by the business enterprise.”8 Both
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