Arizona Supreme Court

Linda Bell, Petitioner v. the Industrial Commission of Arizona, Respondent, Maricopa County, Respondent Employer…

January 30, 2015236 Ariz. 478

Summary

The court held that the statutory seven-day waiting period applies to claims for all forms of disability, including temporary partial disability, and does not require an initial period of temporary total disability. It further held that entitlement requires seven consecutive calendar days of some work-related disability, not necessarily missed work or consecutive working days. Because the administrative findings did not determine whether Bell suffered a qualifying loss of earning capacity lasting seven consecutive days, the court vacated the appellate decision and set aside the administrative award.