The Ohio courts, in their interpretation of the Workmen's Compensation Law, have attempted to establish clear-cut principles of compensability for the working man when his on-the-job injuries are caused by the forces of nature and acts of God. However, the attempts of the courts to establish rules of compensability fail to provide predictability and consistency. The principles proposed are inadequate to cover all the situations that may arise.
Thomas Parker Hayes,
Positional Risk, Forces of Nature, and Workmen's Compensation,
19 Clev. St. L. Rev.
available at http://engagedscholarship.csuohio.edu/clevstlrev/vol19/iss2/36