John R France v. ica/gila county/acip

Summary

The court held that a work-related mental injury is compensable under A.R.S. § 23-1043.01(B) when a specific injury-causing event is objectively unexpected, unusual, or extraordinary, judged from the perspective of a reasonable employee with the claimant’s same or similar duties and training. The administrative law judge applied the wrong standard by considering only whether the possibility of using lethal force was within a deputy’s job duties, rather than evaluating the specific shooting incident. The court vacated the court of appeals’ opinion and set aside the Industrial Commission’s denial of benefits.