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The law of Arkansas states that it is the policy of the state to relieve and reduce to a minimum the suffering and the loss which follow in part from injury to workmen engaged in the service and business of the state, and to provide benefits to their dependents. Troyer v. Doyle, 344 Ark. 84, 40 S.W.3d 292 (2001). This court has recognized that a shoulder prosthesis constitutes an adjunct or appendage to the body and as such, a shoulder prosthesis is a form of medical equipment. Hackett v. National Rubber Prods., Inc., 284 Ark. 499, 505, 683 S.W.2d 942, 945 (1985). In addition, the legislature set forth in Ark. Code Ann. § 16-22-308, the Employer's Liability Act, the defense that manufacturer of any such medical equipment was liable for all damages sustained by the employee, and thus the employer was precluded from shifting the entire loss to the insurance carrier. Hackett, 284 Ark. at 505, 683 S.W.2d at 945. If the employer was precluded from shifting the entire loss to the insurance carrier, and a manufacturer could be held liable to the injured employee for its product, then a manufacturer's employees should likewise be exposed to liability under the Employer's Liability Act. Id.
The following three factors must be considered when determining whether a particular activity is protected by the workers' compensation laws: (1) the nature of the benefit to the employer, (2) the work relationship of the employee to the employer, and (3) the business relationship of the employee to the employer. Ewing v. My Sister's Place, Inc., 367 Ark. 177, 238 S.W.3d 24 (2006). The compensability of an injury under the Workers' Compensation Act is based on the relationship of the injury to the business of the employer rather than the individual employment relationship of the victim. id.
Arkansas law has long recognized that the doctrine of recreational use immunity is a defense to a plaintiff's claim for injuries received while participating in an activity on the land of another. Mountain Home Baptist Church, Inc. v. Karas, 578 Ark. 501, 250 S.W.3d 335 (2007). 7211a4ac4a