After the employee parked his vehicle in the employer's parking lot, he opened the vehicle's door, put one leg out of the door, placed his foot on the ground, and turned to the right to pick up his ""dinner pail"". As he twisted back towards the open door, he felt a snap in his back. Pain immediately ran down his left leg and up his back. Later, an MRI showed a disc herniation and disc bulging in his low back. The Magistrate denied benefits, finding that the circumstances of the employee's employment neither caused nor aggravated an injury nor increased the risk of injury. The Magistrate also held that the case did not fall within the ""going to and coming from work"" presumption of compensability in MCL 418.301(3). The Workers' Compensation Appellate Commission affirmed the Magistrate's denial of benefits. In Ruthruff v Tower Holding Corporation, _____ Mich App _____; ______NW2d_____ (March 18, 2004), the Michigan Court of Appeals reversed the Appellate Commission and remanded the case to the Magistrate for further fact finding. The Court of Appeals held that the Appellate Commission incorrectly applied the law in declining to apply the statutory presumption that an injury is compensable when it occurs when the employee is coming to or going from work. The Court of Appeals remanded the case to the Magistrate, directing the Magistrate to reopen the record and obtain evidence ""regarding the need of plaintiff to bring a lunch to work"". If the employee was not required to bring a lunch, then the risk was of a personal nature and the employee's injury was not compensable. However, if the employee was required to bring a lunch, there could be a sufficient employment cause of the risk which caused the employee's injury.