Justia Arizona Supreme Court Opinion Summaries

The Supreme Court set aside an administrative law judge's (ALJ) denial of Gilbert Aguirre's workers' compensation claim for benefits, holding that a claimant does not waive appellate review of the legally sufficiency of findings before the Industrial Commission of Arizona (ICA).In Post v. Industrial Commission of Arizona, 160 Ariz. 4, 7-9 (1989), the Supreme Court held that when an ALJ fails to make findings on all material issues necessary to resolve the case the award is legally deficient and must be set aside. In this case, after an ALJ denied Aguirre's claim for benefits he filed a request for administrative review. In his request, Aguirre did not specifically challenge the ALJ's failure to make material findings as required by Post. The ALJ summarily affirmed the award. The court of appeals set aside the award based on the absence of legally-sufficient findings. At issue on appeal was whether, because Aguirre did not challenge the lack of material findings required by Post in his request for review, Appellant waived appellate review on that issue. The Supreme Court disagreed, holding that the ALJ's award was legally deficient and must be set aside regardless of whether Aguirre raised the issue. View "Aguirre v. Industrial Commission of Arizona" on Justia Law

At issue was whether Arizona’s automatic assignment provision in Ariz. Rev. Stat. 23-1023(B) applies when an employee receives workers’ compensation benefits under another state’s laws. The Supreme Court held that the law of the state in which the employee’s workers’ compensation is paid determines the assignment rights of the employer and employee, thus reversing the superior court’s grant of summary judgment in favor of the third-party tortfeasor in this case.Plaintiff, a South Carolina resident, was employed as a semi-trick driver with a Nebraska limited liability company, which, in turn, contracted with Defendant, an Arizona company, to provide training for Plaintiff in Arizona. Plaintiff was a passenger in a semi-truck driving by Defendant’s employee was the truck rolled, injuring Plaintiff. Plaintiff received workers’ compensation in Nebraska paid for by the LLC. Plaintiff then filed this personal injury action against Defendant. The Supreme Court granted summary judgment in favor of Defendant, concluding that, pursuant to section 23-1023(B), Plaintiff had no legal interest in the action. The Supreme Court reversed, holding (1) because Plaintiff received workers’ compensation benefits in Nebraska, Nebraska’s law regarding assignment applied to her claims against Defendant in this action; and (2) because Nebraska does not have an automatic assignment provision, Plaintiff had a legal interest in those claims. View "Jackson v. Eagle KMC LLC" on Justia Law

At issue in this workers’ compensation case was whether, when a worker settles a claim against a third party for less than the limits of the third party’s insurance, the worker may obtain a judicial determination of whether the insurance carrier’s lien should be reduced to account for the employer’s comparative fault.Victor Leija died during the course of his employment. Victor’s family claimed workers’ compensation benefits through Twin City Fire Insurance Company, Victor’s employer’s workers’ compensation carrier. Twin City accepted the claim. The Leijas also filed a negligence action against third parties who allegedly negligently caused Victor’s death. Meanwhile, Twin City asserted its right under Ariz. Rev. Stat. 23-1023(D) to fully enforce a lien against all settlement proceeds to the extent of past and future workers’ compensation benefits. After the Leijas and the third-party defendants settled, Twin City filed this action to fully enforce its lien. The Leijas counterclaimed, requesting that the superior court set a trial to establish the employer’s proportionate fault and the resulting amount of Twin City’s lien. The superior court ruled in Twin City’s favor. The Supreme Court affirmed, holding that a claimant who settles all third-party claims is not entitled to a post-settlement trial to determine the percentage of employer fault solely to reduce or extinguish the insurance carrier’s lien. View "Twin City Fire Insurance Co. v. Leija" on Justia Law

Proposition 206, “The Fair Wages and Healthy Families Act,” which increased the minimum wage and established earn paid sick leave, does not violate the Arizona Constitution’s Revenue Source Rule, Separate Amendment Rule, or Single Subject Rule.Proposition 206 was approved by the Arizona electorate in the November 2016 election. The Proposition increases Arizona’s minimum wage incrementally over a three-year period and then requires annual increases. It also requires employers to provide mandatory sick leave of one hour for every thirty hours worked. Petitioners filed suit seeking a declaration that Proposition 206 is unconstitutional and also sought to preliminarily enjoin implementation and enforcement of the Proposition. The superior court denied a preliminary injunction. Petitioner subsequently sought special action relief with the Supreme Court. The Supreme Court denied relief, holding that Proposition 206 does not violate the identified provisions in the Arizona Constitution. View "Arizona Chamber of Commerce v. Honorable Daniel J. Kiley" on Justia Law

In this employment dispute, Employee filed an action in superior court alleging an unjust enrichment claim against Employee. Employee moved to compel arbitration under the parties’ employment contract’s arbitration provision and brought a claim for severance pay. The superior court granted the motion. Employer asserted various counterclaims. The arbitrator ruled in favor of Employer, finding that Employer properly rescinded the contract based on Employee’s underlying misrepresentations and omissions. The final arbitration award fully settled all claims and counterclaims submitted. The superior court confirmed the award but also granted Employer leave to amend its complaint to reassert its counterclaims. The superior court granted Employer’s motion to amend its complaint. The Supreme Court reversed, holding that Employer, having not specifically challenged the contract’s arbitration provision, may not amend its complaint and litigate its various claims against Employee in this action. View "Hamblen v. Honorable Ralph Hatch" on Justia Law

The Arizona State Retirement System (ASRS) operates a defined-benefit plan for state employees and participating political subdivisions. The City of Chandler operated a deferred-compensation plan in which it contributed money for its employees and permitted employees to defer additional amounts, which were held in trust until distributed to employees, generally at age seventy and one-half. Mary Wade and Marla Paddock, City employees, filed a complaint against ASRS and others on behalf of themselves, arguing that City-contributed payments into the deferred-compensation-plan trust constituted “compensation” for the purpose of calculating ASRS contributions and benefits. The trial court entered summary judgment in favor of the City. The court of appeals reversed, concluding that the term “salary” included the City’s regular contributions to the deferred-compensation-plan. The Supreme Court largely affirmed, holding that the City’s contractually required contributions into the deferred-compensation-plan trust for the benefit of its employees formed part of their salary and was “compensation” under Ariz. Rev. Stat. 38-711(7). View "Wade v. Arizona State Retirement System" on Justia Law

In 2011, the Arizona Legislature enacted Senate Bill 1609, which changed the Elected Officials’ Retirement Plan by changing the formula for calculating future benefit increases for retired Plan members and increased the amount that employed Plan members must contribute toward their pensions. Employed members of the Plan challenged the Bill, arguing that the unilateral changes to the benefit increases formula and to the amount they were required to contribute toward their pensions violated the Pension Clause and that the legislature could not unilaterally change the terms of their pensions to their detriment. The trial court agreed and invalidated the provisions at issue. The Supreme Court (1) affirmed the grant of summary judgment to the employed Plan members, holding that the Bill’s change to the benefit increases formula and the contribution rate violates the Pension Clause and the Court’s holding in Yeazell v. Copins; and (2) contrary to the trial court’s ruling, the employed members are entitled to attorneys’ fees and prejudgment interest, and the judgment must run against the State as well as the Plan. View "Honorable Philip Hall v. Elected Officials’ Retirement Plan" on Justia Law

Charles Stenz suffered a workplace injury. His employer’s insurance carrier, Pinnacle Risk Management, accepted Stenz’s claim and paid the benefits. Stenz subsequently died, and his widow, Elizabeth Stenz, filed a claim for death benefits. An administrative law judge (ALJ) upheld the denial. The court of appeals set aside the award. The ALJ eventually awarded death benefits and, almost four years after Elizabeth filed her claim, entered a final order affirming the award. Pinnacle paid the benefits dating back to Stenz’s death but did not pay interest on the unpaid benefits. The ALJ concluded that no interest was owed on the death benefit before the award became final. The court of appeals set this ruling aside, concluding that the claim was liquidated as of the date Pinnacle received notice of it. The Supreme Court vacated the opinion of the court of appeals and set aside the ALJ’s award, holding that a claim for death benefits filed pursuant to Ariz. Rev. Stat. 23-1046 is a liquidated claim, and interest is owed on the claim from the date on which the carrier receives notice that a survivor has filed a claim with the Industrial Commission. View "Stenz v. Indus. Comm’n of Ariz." on Justia Law

Linda Bell was injured at her job and underwent surgery for her injury seventeen months later. Bell requested temporary partial disability (TPD) compensation to reimburse her for the sick leave and vacation time she had used following her injury and before her surgery. The Industrial Commission of Arizona (ICA) denied the request on the ground that Bell did not had not taken time off work during the time period for which benefits were requested and that she did not miss any period of time over one week. The court of appeals affirmed on the ground that Bell failed to prove she had satisfied the waiting period created by Ariz. Rev. Stat. 23-1062(B). The Supreme Court vacated the court of appeals’ opinion and set aside the ICA award, holding (1) the waiting period for compensation set forth in section 23-1062(B) applies to claims for all types of disability including both TPD benefits and temporary total disability (TTD) benefits; and (2) section 23-1062(B) does not require proof of an initial period of TTD but does require proof of seven consecutive calendar days of some type of work-related disability before an injured employee becomes entitled to compensation for any type of disability. View "Bell v. Indus. Comm’n of Ariz." on Justia Law

In 1985, the Arizona Legislature established the Elected Officials’ Retirement Plan (“Plan”), which provides pension benefits for elected officials, including judges. Ariz. Rev. Stat. 38-818 establishes a formula for calculating pension benefit increased for retired members of the Plan. In 2011, the Legislature enacted S.B. 1609, which modified the formula set forth in section 38-818. Two retired judges, on behalf of themselves and as representatives of a class of retired Plan members and beneficiaries, sued the Plan and its board members, alleging that S.B. 1609 violated Ariz. Const. art. 29, 1(C). The trial court ruled in favor of Plaintiffs, concluding that S.B. 1609 violated Article 29, 1(C)’s prohibition against the diminishment or impairment of public retirement system benefits. The Supreme Court affirmed, holding that because the statute diminished and impaired the Plan’s retired members’ benefits, it violated the Pension Clause of Article 29, 1(C). View "Fields v. Elected Officials’ Ret. Plan" on Justia Law