Deborah Simmons sued Solo after her son, a Solo employee, was shot and killed at work by a coworker who believed he had stolen money from a lost bag found in the plant restroom. The issue was whether the Workers’ Compensation Act provided the exclusive remedy and barred the wrongful-death suit. The Court of Appeals of Georgia reversed the dismissal. It held that the death did not arise out of employment because the shooting stemmed from a personal dispute between the assailant and the decedent, not from a work-created risk. The reasoning distinguished positional-risk cases involving neutral workplace dangers and concluded that Andrews was targeted for reasons personal to him, which placed the case outside workers’ compensation exclusivity and allowed the civil action to proceed.