Arizona Supreme Court
Jesus Gutierrez v. ica/masterson
April 21, 2011
Summary
The court held that the administrative rule's reference to the "most recent edition" of the AMA Guides means the edition published before the claimant's impairment is rated, not the edition current when the rule was adopted. It also held that this interpretation does not unlawfully delegate legislative authority because the rule recommends, rather than requires, use of the AMA Guides. The court affirmed the court of appeals and the Industrial Commission's decision. No separate opinions were provided.