dissenting.
Mr. Custer, whose work was over for the day, was no longer “in the course of his employment” at the time of this injury.
I start with the observation that the claimant’s injuries bore a circumstantial or positional relationship to his employment. The claimant, a few minutes before the accident, had been engaged in work for his employer; and, were it not for his work, he presumably would have been somewhere else at the time of the accident. Because of the positional relationship of the injury to his employment, and because of natural sympathy as to his injuries, there is a huge temptation to construe the Workers’ Compensation Act in such a way as to award compensation for these injuries. What is troubling, however, is the question of whether, as a matter of statutory interpretation, we can reasonably rule that this injury arose “in the course of’ his employment, within the meaning of section 287.020.3.
Inherent in this inquiry is the question of how we are to approach this case. If we are, as section 287.800 says, to construe the terms of the statute liberally, “with a view to the public welfare,” are we to apply the law with a built-in bias in favor of the claimant in our proceedings under the act? I pause to consider this question before proceeding further with the analysis.
The workers’ compensation law is “entirely a creature of statute.” Greenlee v. Dukes Plastering Service, 75 S.W.3d 273, 276 (Mo. banc 2002). Therefore, our judicial decisions must start and end with the statutory language. We must yield to legislative policy as expressed in the language employed by the General Assembly.
Sections 1.010 and 1.090 are provided by the General Assembly to guide us in the interpretation of its enactments.
... [N]o act of the general assembly or law of this state shall be held to be invalid, or limited in' its scope or effect by the courts of this state, for the reason that it is in derogation of the common law, or with such statutes or acts of parliament [of England]; but all acts of the general assembly, or laws, shall be *619liberally construed, so as to effectuate the true intent and meaning thereof.
Section 1.010, RSMo 2000.
Words and phrases shall be taken in their plain or ordinary and usual sense, but technical words and phrases having a peculiar and appropriate meaning in law shall be understood according to their technical import.
Section 1.090, RSMo 2000.
Also, as already mentioned, the Workers’ Compensation Act itself includes a provision relating to judicial interpretation and application of the Act:
All of the provisions of this chapter shall be liberally construed with a view to the public welfare and a substantial compliance therewith shall be sufficient to give effect to rules, regulations, requirements, awards, orders or decisions of the division and the commission, and they shall not be declared inoperative, illegal or void for any omission of a technical nature in respect thereto.
§ 287.800, RSMo 2000.1
In 1925, after two prior workers’ compensation enactments had been defeated by public referendum, a compensation law that was supported by both labor and business groups was enacted with broad public approval. R. Robert Cohn, HistoRY of Workmen’s Compensation Law, reprinted in 15 V.A.M.S. 17-52 (1965), at 22-24. The act codified the common law principle that the employer had a responsibility to provide a reasonably safe place to work and a reasonably safe method of work. See Kelso v. W.A. Ross Const. Co., 337 Mo. 202, 85 S.W.2d 527, 534 (1935); See also COHN at 24-25. It replaced that part of the common law that required that the employee prove the employer’s negligence, and it abrogated the traditional common law defenses, such as contributory negligence. Id. at 22-24. The act thus eliminated courtroom contentions about fault between employer and employee while providing a modest but relatively definite remedy for workers injured on the job.
It hardly needs to be said that under the common law no employer had a duty to ensure that employees arrived home safely after work, regardless of the location of the work site. The statute similarly limited compensation to injuries arising “out of’ and “in the course of’ employment. § 287.020.3. The act provides compensation only for injuries occurring during the employee’s work at a place where the work required the worker to be. See § 287.020.5. Thus neither the common law, the history of the act, nor the language of the act suggests that any portion of the act was aimed at adding a requirement that employers take responsibility for getting them employees safely home after the employees had finished work and had left the work premises.
Section 1.010 rebuts the notion that an act in derogation of the common law must be construed strictly. It cautions against the strict application of legal technicalities in a way that would undermine the purposes of the act. The Workers’ Compensation Act, like all other statutes, is thus to be construed liberally to effectuate its true purposes. This would obviously mean construing the statute in a way that is not narrow and not begrudging and not with undue emphasis on technicalities, so that the purposes of the statute are not undermined.
In section 287.800, the legislature said the workers’ compensation statute is to be *620construed liberally with a “view to the public welfare,” choosing to use the exact phrase that had been used earlier with regard to interpretation of the terms of the Public Service Commission Act.2 The legislature did not say to construe the statute with a view to “claimant welfare.” It is not clear that the phrase “public welfare” is always equivalent to “claimant welfare,” though in any given case there may be practical overlap of these concepts.3
Section 1.090 exhorts the courts to take the words and phrases of the statutes in their “plain or ordinary and usual sense.” That principle can be applied harmoniously with the principle of liberal construction with a view to the public welfare.
Section 76 of the act provides that “all of the provisions of this act shall be liberally construed with a view to the public welfare,” etc, evidently intending that the act shall be so construed as not to be unnecessarily restricted by a technical construction of the words used therein, but rather that such words be construed in the broader, popular sense.
Drecksmith v. Universal Carloading & Distrib. Co., 18 S.W.2d 86, 87 (Mo.App. 1929). As the Missouri Supreme Court stated in 1933, liberal construction of the Workers’ Compensation Act “does not authorize extending the terms of the act beyond what they plainly say.” State ex rel. Sei v. Haid, 332 Mo. 1061, 61 S.W.2d 950, 954 (1933). Thus, there can be a type of liberal construction that is faithful to both the plain text and the purposes of the act. A few courts have suggested that a liberal construction “with a view to the public welfare” does not necessarily mean that the compensation proceedings must be biased in favor of the claimant. See, e.g. Reed v. Kansas City Wholesale Grocery Co., 236 Mo.App. 402, 156 S.W.2d 747 (1941):
The liberal construction that is required [of the Workmen’s Compensation law] is “with a view to the public welfare.” This does not mean that any strained construction of the law should be made or allowed for the purpose of permitting an exorbitant award solely for private gain. This would clearly be opposed to the public welfare and the public policy of the state as exemplified in the Compensation Law. The liberal construction that is meant here is that the law shall be applied so that a claimant will be considered within its scope if reasonably possible, and, that while the law should be liberally construed to that end, it should also be justly administered with equal equity to both the employer and the employee.
Id. at 753.
We have used some phrases that can hinder our efforts to understand and properly harmonize these principles. For instance, the majority opinion states that the law “is intended to extend its benefits to *621the largest possible class.”4 Although the Missouri Supreme Court has seldom chosen to use this phrase,5 our intermediate appellate courts have used it with increasing frequency, with two-thirds of the seventy-five reported cases in Missouri using this phrase having been issued since 1989. The phrase could be thought of as supporting the notion that every injury that could “possibly” be considered to be compensa-ble should be held to be compensable.
Such notion, however, does not square with either the Workers’ Compensation Act itself or with the Supreme Court’s pronouncement as to the standard of review. See Hampton v. Big Boy Steel Erection, 121 S.W.3d 220, 223 (Mo. banc 2003):
There is nothing in the constitution or section 287.495.1 that requires a reviewing court to view the evidence and all favorable inferences drawn therefrom in the light most favorable to the award.
Id.
The notion that “any question” or “any doubt” as to compensability is to be resolved in favor of the employee originated, at least in part, I believe, from cases commenting on the liberal construction to be applied to the terms of the act. In Dauster v. Star Manufacturing Co., 145 S.W.2d 499, 503 (Mo.App.1940), for instance, the court expressed the view that, in accordance with the broad construction enjoined by section 287.800, any question as to the meaning of a term of the act should be resolved in favor of the claimant. The phraseology was modified in subsequent cases (citing Dauster) so that now it is not uncommon for the Commission or a court to say that “all doubts [implying ‘all doubts of any kind,’ not merely doubts about the meaning of a word or a phrase in the *622statute] should be resolved in favor of the employee.” See, e.g., Baer v. City of Brookfield, 366 S.W.2d 469, 471 (Mo.App. 1963); Rogers v. Pacesetter Corp., 972 S.W.2d 540, 542 (Mo.App.1998); Brenneisen v. Leach’s Standard Serv. Station, 806 S.W.2d 443, 445 (Mo.App.1991).
While the Missouri Supreme Court has occasionally used this terminology, it has used it only in connection with actually construing a term of the act, see, e.g., Wolfgeher v. Wagner Cartage Service, Inc., 646 S.W.2d 781, 783 (Mo.1983) (construing the term “accident” broadly), or in obiter dictum, where the terminology did not govern the result, see Kelley v. Sohio Chemical Co., 392 S.W.2d 255, 259 (Mo.1965) (upholding a denial of compensation).
Although in actual practice the courts do not always resolve “all doubts” in favor of the claimant, we sometimes give the impression that the rule we are following is that compensation must be allowed whenever it is possible to conceive of any kind of basis for compensability. This impression stands in contrast to the earlier suggestion that while the act is to be liberally construed with a view to the public welfare, the law should be “justly administered with equal equity to both employer and employee.” Reed v. Kansas City Wholesale Grocery Co., 236 Mo.App. 402, 156 S.W.2d 747, 753 (1941). Neither liberal construction of statutory terms with a view to the public welfare, as the statute calls for, nor liberal construction of statutory terms favoring the claimant (which may often as a practical matter be the same thing), “authorize extending the terms of the act beyond what they plainly say.” Raid, 61 S.W.2d at 954. The act is to be construed so as to give effect to the “plain and ordinary meaning” of the words “if possible.” Greenlee v. Dukes Plastering Serv., 75 S.W.3d 273, 276 (Mo. banc 2002).
In light of the foregoing, one can see that we are to give a liberal construction to the scope of the act, with a view to the public welfare, so as not to exclude any class of workers that the legislature would not have intended to exclude. § 287.800. We are also to favor a broader rather than a narrower interpretation of the terms of the act. Id. This will result in injuries and occupational diseases being deemed com-pensable as they are reasonably determined to fit within the plain and ordinary meaning of the statutory terms, including definitions. We are to give effect to the plain words in their ordinary meaning as much as possible. Greenlee, 75 S.W.3d at 276; Pierson v. Treasurer of Mo., 126 S.W.3d 386, 390 (Mo. banc 2004); section 1.090. In reviewing a record, we are to view the evidence and the factual findings objectively, determining whether the ruling of the Commission is supported by competent and substantial evidence in the context of the whole record. See Hampton v. Big Boy Steel Erection, 121 S.W.3d at 223.
Our task of analysis here is also affected by the 1993 amendments to the Workers’ Compensation Act. In that year, the Missouri General Assembly, apparently not content with some existing approaches of the Commission and the courts, adopted statutory changes which seemed, on their face, designed to limit, rather than expand, compensability in certain cases. Prior to the 1993 amendments, section 287.020.2 only served to define the word “accident.” The 1993 revision added the following sentences to that subsection:
An injury is compensable if it is clearly work related. An injury is clearly work related if work was a substantial factor in the cause of the resulting medical condition or disability. An injury is not compensable merely because work was a triggering or precipitating factor.
*623Section 287.020.2.6 This language was not previously a part of the act.
With this amendment, the General Assembly indicated it wanted to exclude from compensation those injuries or conditions where the injury was not substantially related to the employment but was only “triggered” or “precipitated” by the employment. § 287.020.2. That amendment only serves, in my view, to make clearer in this case what would otherwise have been already clear about whether the claimant here was in the course of his employment.
When the only relationship between the work and the injury is that the injury occurred in a traffic accident while the employee was traveling home from a different worksite than usual, it would seem to be an instance of the work merely “precipitating,” or merely “providing an occasion” for the injury. See Bear v. Anson Implement, Inc., 976 S.W.2d 553, 556-57 (Mo.App.1998).
The majority in this case prefers to engage in discussion of the “coming and going rule” and its judicially crafted exceptions.7 While this practice may often be useful, it can also, unfortunately, cause failure to consider whether the worker was “in the course of employment” as that phrase is ordinarily understood.8 See, e.g., Brown v. Mid-Central Fish Company, 641 S.W.2d 785 (Mo.App.1982), which is discussed in the majority opinion.
Mr. Custer frequently traveled (or “extensively traveled,” in the words of the majority opinion) to other portions of the metropolitan area to call on customers and agents. There is no dispute that Mr. Custer had an office at his employer’s local headquarters and that he regularly spent a substantial amount of his work time, if not the majority of his work time, at that office. There is also no dispute that he was not in the process of returning to the office for some employment purpose at the time of the accident. There is also no dispute that this event was in the metropolitan area, not in another community.
Once the golf event was over, Mr. Custer was on his own time. He could go *624home or wherever he wished to go. He was in the metropolitan area. His employer had no say over where he resided, where he would go following the golf event, or what route he would take to get wherever he was going. He was no longer, under any normal or ordinary understanding of the phrase, “in the course of his employment” at the time of his injury. Nor, in the words of section 287.020.5, RSMo 2000, was he “engaged in or about the premises where [his] duties [were] being performed, or where [his] services require[d][his] presence as a part of such service.”
In this case, there is no doubt about the plain and ordinary meaning of the phrase “course of employment.” There is also no doubt about the material facts, which the parties agree upon. While some cases are extremely difficult to resolve, this one is not, once one gets past the erroneous notion that the case must be governed by decisions discussing the “coming and going rule” and its exceptions.
Contrary to what the majority implies, the Missouri Supreme Court has never suggested that we should routinely jettison analysis based on the plain meaning of the statutory terms and base our analysis on the going and coming rule and its exceptions. Moreover, although the ruling that I suggest in this case may seem contrary to a few intermediate appellate decisions,9 it is not precluded by any decision of the Missouri Supreme Court.
One decision of the Missouri Supreme Court relied upon significantly by the majority is Brown v. Weber Implement & Auto Company, 357 Mo. 1, 206 S.W.2d 350, 351 (1947). That case involved a salesman who had made a sales call at a yacht club, then stayed at the yacht club with his wife and some friends for several hours, then was injured on the way home. The Court’s affirmance in that case noted that the evidence was such that it also could have supported an award for the employer. That decision, which was based in part on the conflict in the testimony, was prior to the Supreme Court’s decision in Hampton v. Big Boy Steel Erection, supra, which specified a different standard of reviewing the facts. It was also prior to the 1993 amendments. Finally, it involved an employee involved in outside sales rather than an employee who spends part of his time in social contacts with customers and agents. An outside sales person is ordinarily in the course of his or her employment whenever driving during the work day. Thus, in my view, it is distinguishable and does not dictate an award for the claimant in this case.
The fact that the claimant drove a company car, like the fact that golf ordinarily is recreational, is immaterial in this case. The car was freely available to the claimant for personal as well as business purposes. The employer did not restrict the use of the vehicle in any way. The record does not show that when the claimant drove the vehicle for personal use, there *625was any benefit to the employer such as would be provided from advertising written on the side of the car. See Otte v. Langley’s Lawn Care, Inc., 66 S.W.3d 64, 67 (Mo.App.2001). Also, this is not like the case of a car salesman driving a demonstrator under the strict rules of the employer, as in Hill v. Royal Gate Dodge, 887 S.W.2d 640, 641 (Mo.App.1994). Nor does it involve a demonstrator car used “strictly for business purposes,” as in Reece v. Neal Chevrolet & Universal Underwriters Insurance Co., 912 S.W.2d 599, 601 (Mo.App.1995).
There was no evidence presented at the hearing as to the employer’s purpose in providing the car. Perhaps, for all we know, the provision of the vehicle in this case was simply a form of additional compensation to a valuable employee. We have no information from which the Commission could have concluded in these circumstances that the use of the company car placed the claimant in the course of his employment. Whether the employee was driving home from work, going to work, or was engaged in a shopping errand to the store, the use of the company car does not place him in the course of his employment. On the other hand, when the claimant was driving to a customer relations event for his employer during the work day, he was “in the course of his employment” regardless of who owned the car he was driving. The ownership of the car is a classic “red herring.”
Bear v. Anson Implement, Inc., 976 S.W.2d 553 (Mo.App.1998), relied upon by the employer in this case, was resolved in accordance with the plain language of the statute although the court also discussed the “going and coming rule.” In Bear, the employee was released from his regular work early to go to a medical appointment for a work-related injury. He attended his 5:00 PM employer-authorized medical appointment, which extended past the regular work hours. On his way home from the medical center (which was not his normal worksite), his vehicle was struck by another vehicle that crossed the highway center line. Id. at 555. Thus, the injury had a “positional risk” relationship to the work. That is, if it had not been for the original work-related injury, he would not have been going home at the later hour on the route in question. It was because of the work that he was driving on the highway at that precise time in the evening traffic.
This court in Bear, however, found that the claimant was not engaged in the course of his employment at the time. The court said that it was not sufficient that the work “simply furnished an occasion for an injury,” or that the work “caused him to be at the place where it happened.” Id. at 556-57. The employee was finished with his work-related activities for the day. He was not going back to work. He was free to go home or wherever he wished for his own purposes. Id. at 558. He was not where his employment required him to be to perform his employment. Bear accords with a normal, everyday understanding of the phrase “in the course of employment.” See also Snowbarger v. M.F.A. Cent. Coop., 349 S.W.2d 224, 226 (Mo. banc 1961) (auto accident while en -route to see his family doctor for work-related medical treatment; held not in the course of employment). Had the claimant spoken to a family member or friend on the phone just after leaving the golf course, and had he been asked, “are you still at work,” he would not have answered in the affirmative.
Just as this court did in Bear, we should apply the plain and ordinary meaning of the phrase in question. Our attempt to liberally construe the phrase with a view to the public welfare does not require or jus*626tify going beyond the plain and ordinary meaning. It does not permit us to say that the act of driving home from a golf course some 30 or 40 miles from the claimant’s home in his own metropolitan area— not an extraordinary distance within the area — is “in the course of’ his employment. To reach that conclusion would expand the terms of the statute. Moreover, it would raise many unanswered and perplexing questions, such as whether the result would be different if he had played at that golf course regularly, or if the golf course had been only 2 miles from his home, and so on.
Mr. Custer, like the claimant in Bear, was finished with his work-related activities for the day and was free to go home or wherever he wished for his own purposes. His employer was not responsible to get him home safely. There is no ordinary construction of the phrase “course of employment” that would include the activities of Mr. Custer at the time of the accident, though the evidence showed that the employment was positionally related to his injury.
It is not without significance that neither Mr. Custer nor the Commission had a clear theory as to the basis of Mr. Custer’s claim. The Commission looked to the “totality of the circumstances,” which is arguably a feeling-based test. Mr. Custer’s attorney similarly argued that the “bottom line” was the attorney’s “strong feeling” that Mr. Custer “was at work.” These are not statutory concepts; nor do they give adequate guidance.
Conclusion
The 1925 General Assembly, in my view, intended to avoid a narrow construction of the scope of the act and of words like “accident,” “injury,” and “course of employment.” But I do not believe the drafters intended to expand the employer’s responsibility beyond the workplace to include making sure that employees arrive home safely after work. The broad application of words and phrases can go no broader than the boundaries of the plain and ordinary meaning of the terms in question.
The Commission’s decision goes beyond the plain and ordinary meaning of the words “in the course of employment.” The conclusion reached is not supported by substantial and competent evidence on the whole record. Therefore, I submit that we have no choice but to reverse the award of the Commission.
ULRICH and SPINDEN, 33., concur in the dissent.
. An original part of the 1925 statute. See Section 13672a75 of Chapter 128A, 1927 Supp. to Missouri Revised Statutes.
. "A substantial compliance with the requirements of this act shall be sufficient to give effect to all the rules, orders, acts and regulations of the commission, and they shall not be declared inoperative, illegal or void for any omission of a technical nature in respect thereto. The provisions of this act shall be liberally construed with a view to the public welfare, efficient facilities and substantial justice between patrons and public utilities.” Section 127 of the Public Service Commission Act, Laws 1913, p. 648. (Emphasis added.)
. As the majority mentions, while this case was pending, the General Assembly enacted changes to section 287.800 as well as other portion of the Worker’s Compensation Act. Senate Bill 1, effective August 28, 2005. The change to 287.800 provides that the provisions of the Worker's Compensation Act are to be “construed strictly.”
. Originally, the phrase was used in a particular context. Borrowing the language of a Vermont case, the Missouri Supreme Court employed the phrase in the context of determining the scope of one of the exceptions from coverage. Klasing v. Fred Schmitt Contracting Co., 335 Mo. 721, 73 S.W.2d 1011, 1014 (1934). In Klasing, the employee recovered a personal injury damage award against his employer after pleading exemption from the act because his "average annual earnings” exceeded $3,600 per year. Id. at 1012. During the year of the accident, the employee earned more than $3,600 per year. Id. The court construed the statutory phrase "average annual earnings” to include consideration of two prior work years under the same employer (so there were some other years to "average” beside the year in which the accident occurred). Because the employee made less in the two prior years than in the year of the injury, the "average” did not exceed $3,600 per year. Thus, the court vacated the employee’s $15,000 personal injury award on the ground that the exception did not apply; the compensation act was the exclusive remedy. Id. at 1015. The court did not construe the statutory phrase in question in a way that was favorable to the injured employee. Rather, it avoided a strained construction that would have allowed the employee to keep his personal injury award but would have narrowed the scope of the act by narrowing the class of workers governed by the act. The only other early cases reciting the same rule about the "largest possible class” were also concerned with the scope of the application of the entire statutory scheme in the public interest. See, e.g., Sayles v. Kansas City Structural Steel Co., 344 Mo. 756, 128 S.W.2d 1046 (banc 1939), overruled by Snowbarger v. M.F.A. Cent. Coop., 317 S.W.2d 390, 395 (Mo. banc 1958); State ex rel. Mills v. Allen, 344 Mo. 743, 128 S.W.2d 1040 (banc 1939); Metzinger v. H.A. Dailey, Inc., 358 Mo. 689, 216 S.W.2d 480 (1948); Dost v. Pevely Dairy Company, 273 S.W.2d 242 (1954).
. The first and only Supreme Court case to use this phrase in a context other than the construction of a statutory exclusion to coverage was Wolfgeher v. Wagner Cartage Service, Inc., 646 S.W.2d 781 (Mo.1983), in which the court broadly construed the term "accident.” The Missouri Supreme Court has never quoted this phrase to justify construing all factual possibilities in favor of the claimant.
. Also, the General Assembly in 1993 decided in the revisions to provide more specific guidelines for determining when an injury has arisen "out of and in the course of employment.” § 287.020.3(2). The parties here do not discuss these guidelines. Nor does the majority opinion discuss these amendments at all. Because I believe this case is resolved simply on the basis of the plain language of the phrase "in the course of employment,” it is unnecessary to address these guidelines in this opinion.
. This "rule” originally arose in personal injury cases in the context of respondeat superi- or liability of employers. See, e.g., Sharp v. W. & W. Trucking Co., 421 S.W.2d 213, 219 (Mo. banc 1967). Under the "rule” in that context, i.e., if this were a personal injury suit by another driver against the Hartford for Custer’s negligence, Custer probably would not be considered in the course of his employment. Id. Thus, the workers’ compensation cases borrowed the concept from agency law, but we have applied it in compensation cases in a way that is asymmetrical to agency law, because of the broad exceptions in the compensation context.
.In this case, the AU and the Commission extensively discussed the "coming and going rule” and its exceptions before deciding that none of the exceptions were specifically applicable here. The ALJ and the Commission then decided that, in any event, consideration of the "totality of the circumstances” suggested that this injury was compensable. The Commission, in other words, set up the going and coming rule as the basis of analysis, considered the exceptions, then essentially dismissed the whole analysis, thereby in effect attempting to create another exception, the "totality of the circumstances" exception— which, unfortunately, provides no guidance at all. The majority opinion wisely avoids following the Commission's analysis. The majority, however, errs by sticking with a discussion of the rule and its exceptions rather than applying the plain language of the statute.
. Brown v. Mid-Central Fish Co., 641 S.W.2d 785 (Mo.App.1982); Baldridge v. Inter-River Drainage Dist. Of Mo., 645 S.W.2d 139, 140 (Mo.App.1982). I say they seem contrary because I do not agree with the majority that these decisions are sufficiently similar to govern this case. Brown involved a salesman who called on restaurants. He worked entirely on his own schedule, including sometimes late at night. Id. at 786. Baldridge is also different in that there the parties disputed whether the employee was still engaged in his work at the time. Part of his work, which was "more or less” on his own schedule, involved searching for parts and buying items for the dragline and bulldozer operation. At the time of the accident, he had tools, parts and oil in his truck belonging to the employer. Id. at 140-41. While I am not sure either of these decisions are particularly well-reasoned, they do not preclude a ruling for the employer in this case.