Hypl v. Industrial Commission of Arizona
Arizona Court of Appeals
111 P.3d 423 (2005)
- Written by Abby Roughton, JD
Facts
Corexpress (defendant) employed Jaroslav Hypl (plaintiff) to transport wire from Arizona to Texas. Hypl never delivered the wire, and police subsequently arrested Hypl in New Mexico on suspicion of driving while intoxicated. The arresting officer eventually determined that Hypl was injured, and Hypl underwent emergency surgery for a fractured skull and blood clots. Hypl sought workers’-compensation benefits for his injury. At a hearing before an administrative-law judge (ALJ), Hypl testified that he suffered amnesia from the injury and could not remember how the injury occurred. The ALJ concluded that Hypl had not shown that his injury arose out of and occurred in the course of his employment. Although Arizona courts had previously recognized an unexplained-death presumption that allowed the recovery of benefits for an employee’s unexplained death that occurred within the time and space of employment, the ALJ ruled that such a presumption was inapplicable to Hypl because Hypl was alive. The ALJ thus determined that Hypl’s injury was noncompensable. The ALJ’s decision was affirmed on administrative review, and Hypl appealed.
Rule of Law
Issue
Holding and Reasoning (Howard, J.)
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