In Halenar v. Superior Court, 109 Ariz. 27, 504 P.2d 928 (1972), a decedent's survivors sued his coworkers for negligence. The trial court found that Arizona's workers' compensation statutes precluded the action. The Arizona Supreme Court held that the statutes in question, in accordance with the Arizona Constitution, did not preclude an action against fellow employees, but only barred an action against the employer in exchange for statutory benefits. Id.