Narrative Opinion Summary
In this case, the Court of Appeals of Arizona reviewed a decision by the Industrial Commission of Arizona denying a claimant's compensation for injuries sustained in a nonindustrial auto accident. The claimant was returning home from physical therapy for a work-related injury when the accident occurred. The legal issues centered on whether travel for medical treatment of an industrial injury is compensable and if the claimant's deviation from his route home constituted a substantial deviation, affecting his eligibility for compensation. The court confirmed that travel for such medical treatment is generally compensable under workers' compensation laws. However, it upheld the Administrative Law Judge's (A.L.J.) finding that the claimant's deviation from his typical route home was substantial, thereby removing him from coverage. The claimant had pursued a tort claim without notifying his compensation carrier, but the A.L.J. did not consider this factor due to the deviation finding. Ultimately, the court affirmed the denial of compensation, emphasizing that the duration and purpose of the claimant's deviations were significant enough to sever the connection to the work-related injury. Judges Kleinschmidt and O'Melia concurred in this decision.
Legal Issues Addressed
Compensability of Travel for Medical Treatmentsubscribe to see similar legal issues
Application: The court affirmed that travel for medical treatment related to an industrial injury is compensable under workers' compensation statutes.
Reasoning: The court affirmed the finding that travel for medical treatment related to an industrial injury is compensable.
Effect of Settlement on Workers' Compensation Claimssubscribe to see similar legal issues
Application: The claimant's settlement of an automobile tort claim without notifying the compensation carrier did not shield the carrier from liability as it was not considered due to the finding of substantial deviation.
Reasoning: The carrier contends that the employee's settlement of an automobile tort claim without its consent insulates it from liability, but this was not considered by the Administrative Law Judge (A.L.J.) due to a finding of substantial deviation from covered travel.
Going and Coming Rule in Workers' Compensationsubscribe to see similar legal issues
Application: The respondent carrier argued that the going and coming rule applies to travel for medical treatment, but the court noted that travel for necessary medical treatment is akin to a 'special errand' authorized by the employer and thus qualifies for coverage.
Reasoning: The respondent carrier argues that the going and coming rule applies to travel for medical treatment, claiming that accidents occurring during this travel do not arise in the course of employment.
Substantial Deviation from Travel Routesubscribe to see similar legal issues
Application: The claimant's deviation from his usual route home after medical treatment was deemed substantial enough to remove him from workers' compensation coverage.
Reasoning: The Administrative Law Judge (A.L.J.) accepted the claimant's account but concluded it indicated a substantial deviation.