Lawless v. Northern AZ Consolidated Fire Dist - Memorandum Decision - Arizona Court of Appeals - March 4, 2025
- Christopher S. Norton, Esq.
- Mar 4
- 2 min read
Facts:
Shawn Lawless, a firefighter and paramedic, filed a claim for workers' compensation benefits for a mental stress injury, citing events from April 2022.
Lawless had a history of PTSD diagnosed in 2017.
He claimed that responding to two specific incidents on April 1 and April 7, 2022, exacerbated his PTSD.
The Industrial Commission of Arizona (ICA) denied his claim, stating that the stress he experienced was not unexpected, unusual, or extraordinary for his job.
Issue(s):
Did the ALJ err in denying Lawless's application for benefits by finding that the stress he experienced was not unexpected, unusual, or extraordinary?
Does A.R.S. § 23-1043.01(B) violate constitutional equal protection guarantees by treating mental injury claims differently from physical injury claims?
Holding:
The ALJ did not err in denying Lawless's application for benefits. The court found that the stress Lawless experienced was inherent in his job duties and not unexpected, unusual, or extraordinary.
A.R.S. § 23-1043.01(B) does not violate constitutional equal protection guarantees.
The court upheld the statute's requirement for claimants of mental injuries to prove that the injury arose from unexpected, unusual, or extraordinary stress.
Key Takeaways:
The court affirmed the ALJ's decision, emphasizing that the stress Lawless experienced was typical for his role as a firefighter and paramedic.
The court highlighted that the test for compensability under A.R.S.§ 23-1043.01(B) is objective, focusing on whether the work-related event itself imposed unexpected, unusual, or extraordinary stress.
The court rejected Lawless's equal protection argument, noting that the statutory requirements for mental injury claims are consistent with the constitutional provisions of the Workers' Compensation Act.
The court clarified that benefits received under the Officer Craig Tiger Act do not establish entitlement to disability benefits under the Workers' Compensation Act.
Read Full Decision: 1 CA-IC 24-0009 Lawless v. Northern MD.pdf
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