Turner v. Indus. Comm’n of Ariz. (7/15/2021)

August 9, 2021

Arizona Court of Appeals holds a workplace accident caused by an employee’s weakened physical condition does not create a viable workers’ compensation claim.

An eighty-year-old employee at a call center attempted to open the refrigerator in the company’s break room, which caused him to slip and fall.  The fall broke his femur.  That injury required the employee to get surgery and implementation of hardware.  Following his surgery, the employee filed a claim for workers’ compensation, which was denied.  The employee appealed that denial and argued to the ALJ that the company’s refrigerator door got stuck, which caused him to fall.  An ALJ sustained the denial of the claim for compensation, explaining that the video evidence did not support his claim that the door was stuck and caused him to fall.

The Court of Appeals agreed with the ALJ.  To prevail on a workers’ compensation claim, an employee must demonstrate that the injury arose out of his employment with the company.  That is, an employee must show a causal connection between the sustained injury and his employment.  Here, the Court held that the injury was caused by the employee’s weakened physical condition—not his employment with the call center.  The Court explained that the fact that the injury occurred at work, standing alone, is insufficient to establish causation, and sustained the denial of his workers’ compensation claim.

Judge Cruz authored the opinion; Judges Perkins and Howe concurred.