This case law update brought to you by Freeway Law, personal injury and car accident attorneys. The following is not one of our cases, but it is of some significance, and we thought we should share it with our readers for informational purposes. The information below is for informational purposes only and not to be construed as legal advice.
Court: Arizona Supreme Court
Opinion Date: March 2, 2021
Areas of Law: Government & Administrative Law, Labor & Employment Law, Personal Injury
The Supreme Court set aside the decision of administrative law judge (ALJ) for the Industrial Commission of Arizona (ICA) denying the claim for benefits filed by deputy John France, who developed post-traumatic stress disorder after he shot and killed a man, holding that the administrative law judge erred by failing to apply the standard required by Ariz. Rev. Stat. 23-1043.01(B). Under section 23-1043.01(B), employees may receive compensation for mental injuries if an unexpected, unusual or extraordinary employment-related stress was a substantial contributing cause of the mental injury. An ALJ denied France’s claim for benefits, concluding that the shooting incident was not “unusual, unexpected, or extraordinary.” The Supreme Court set aside the ICA’s decision, holding (1) under section 23-1043.01(b), a work-related mental injury is compensable if the specific event causing the injury was objectively “unexpected, unusual or extraordinary”; (2) under this objective standard, an injury-causing event must be examined from the standpoint of a reasonable employee with the same or similar job duties and training as the claimant; and (3) the ALJ erred by limiting her analysis to whether France’s job duties encompassed the possibility of using lethal force in the line of duty and failing to consider whether the shooting incident was unexpected or extraordinary.
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