Matthews v. Industrial Commission of Arizona
Matthews v. Industrial Commission of Arizona (Ariz., Nov. 23, 2022): The Arizona Supreme Court held that a law limiting workers’ compensation claims for mental illness to those arising from “unexpected, unusual or extraordinary” situations did not violate the Arizona Constitution. The state constitution requires the Arizona legislature to enact a law providing coverage for an “injury” due to any employment-related “accident.” Analyzing the terms’ definitions at the time the provision was adopted, the court concluded that “injury” does not include mental harm, and “accident” refers to an unexpected event. The court thus held that the Arizona law expanded workers’ compensation eligibility by allowing for some mental illness claims, rather than unconstitutionally limiting it. The court also found no equal protection violation, concluding that all injured workers are required to prove their injuries arise from unexpected situations, not just those with mental illness. Read the full decision here.