In Manhattan-Dickman Construction Co. v. Shawler, 113 Ariz. 549, 558 P.2d 894 (1976), the attorneys for the defendants in a negligence action "injected and continuously emphasized workers' compensation" during jury selection and the examination of witnesses. Id. at 556-57, 558 P.2d at 901-02. The trial court declined to give an instruction regarding the workers' compensation carrier's statutory lien on the plaintiff's recovery. Id. at 557, 558 P.2d at 902. The supreme court determined the court's failure to instruct the jury was error and directed the court to enter additurs for the plaintiffs. Manhattan-Dickman, 113 Ariz. at 557, 558 P.2d at 902.