City of Phoenix v. Tyken Solie - Memorandum Decision - Arizona Court of Appeals - March 11, 2025

Facts: Tyken Solie, a patrol officer for the City of Phoenix, experienced anxiety and difficulty sleeping after responding to a home-invasion call in 2011. ​ In February 2020, Solie was diagnosed with "unspecified trauma" and stressor-related disorder by Shawna Peters, a licensed professional counselor. ​ In January 2021, Dr. Amy White diagnosed Solie with PTSD, leading Solie to file a workers' compensation claim in May 2021. ​ The City argued the claim was untimely, asserting the filing period began in February 2020 when Solie first sought treatment. ​

Issue(s):

1. Whether Solie's workers' compensation claim was filed within the statutory one-year period after recognizing the nature, seriousness, and probable causal relationship of his injury to his employment. ​

   
   

Holding: The Arizona Court of Appeals affirmed the Industrial Commission of Arizona's decision that Solie's claim was timely filed. The court held that Solie did not recognize the nature of his injury and its causal relationship to his employment until he was diagnosed with PTSD in January 2021. ​

Key Takeaways:

• The one-year filing period for workers' compensation claims begins when the employee recognizes the nature, seriousness, and probable causal relationship of the injury to their employment. ​

• Expert testimony is generally required to assess the timing of a PTSD diagnosis. ​

• Knowledge of symptoms is different from knowledge of the medical condition itself. ​

• The City failed to provide sufficient evidence to prove that Solie should have known of his PTSD before the formal diagnosis in January 2021. ​

Read Full Decision: 1 CA-IC 24-0024 PHOENIX CCMSI v. SOLIE.pdf