NCCI Court Case Update, Arizona – December 2022

Matthews v. The Industrial Commission of Arizona

On November 23, 2022, the Supreme Court of Arizona, in Matthews v. The Industrial Commission of Arizona, upheld the constitutionality of Arizona statute 23-1043.01(B), which limits workers compensation (WC) claims for mental illnesses to those that arise from an "unexpected, unusual, or extraordinary stress" situation.

In this case, a police officer—whose job required him to respond and handle stressful situations—filed a WC claim for mental injuries that arose from an incident at work. After an administrative law judge found the claim non-compensable because the triggering event was not unexpected, unusual, or extraordinary, the police officer appealed, contending that the statute violated article 18, section 8, and the equal protection guarantee of the Arizona constitution.

The court first analyzed article 18, section 8 of the Arizona constitution, which generally states that the legislature is required to enact WC laws that provide coverage for injuries from any accident arising from a necessary risk or danger of the employment. The court reasoned that a stress-related illness was not considered an “injury” when the constitution was enacted in 1912 and thus compensation for mental injuries only exists to the extent that it has been made available through the legislature. Therefore, the court ruled, Arizona statute 23-1043.01(B) does not violate article 18, section 8 because that section did not contemplate mental injuries within its scope.

The court also found that Arizona statute 23-1043.01(B) does not violate the equal protection guarantee of the state constitution because it does not subject workers with stress-related injuries to unconstitutional discrimination.

With this decision, the Supreme Court of Arizona affirmed an appellate ruling which held that Arizona statute 23-1043.01(B) did not violate the state constitution.

For more information on other cases monitored by NCCI’s Legal Division, visit previous Court Case Updates and Court Case Insights, under the Legal section of INSIGHTS on ncci.com.

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