Arizona: Employee’s Fall Due to Idiopathic Condition is Not Compensable

Quoting liberally from Larson’s Workers’ Compensation Law, an Arizona appellate court affirmed a decision by the state’s Industrial Commission that found an employee’s injuries did not arise out of and occur within the course and scope of the employment because the employee’s injuries stemmed from an idiopathic condition—the employee suffered from an altered gait due to a prior injury. The employee, who worked for a temporary staffing company, had been placed with a regional call center. During a break one evening, the employee fell while opening a refrigerator. He suffered a fractured femur. A videotape showed that as the employee sought to open the door of the refrigerator, he shifted his left leg and foot behind his right, catching the toe of his left shoe on his right heel, causing him to lose his balance and fall. According to medical testimony offered at the hearing, the employee had his knee replaced several times since 2006 and was at risk for such a fall due to his age, altered gait, and medical history. In its unpublished decision, the appellate court agreed that under these circumstances, substantial evidence supported the Commission’s findings that claimant had failed to show a causal connection between his injury and the work environment.

Thomas A. Robinson, J.D., the co-Editor-in-Chief and Feature National Columnist for the LexisNexis Workers’ Compensation eNewsletter, is co-author of Larson’s Workers’ Compensation Law(LexisNexis).

LexisNexis Online Subscribers: Citations below link to Lexis Advance.

See Turner v. Industrial Comm’n of Ariz., 2021 Ariz. App. Unpub. LEXIS 517 (May 6, 2021)

See generally Larson’s Workers’ Compensation Law, § 9.01.

Source: Larson’s Workers’ Compensation Law, the nation’s leading authority on workers’ compensation law

For a more detailed discussion of the case, see

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