A.R.S. 23-1031 Interpretation
In Aranda v. Industrial Commission, 198 Ariz. 467, 11 P.3d 1006 (2000), the supreme court of Arizona addressed whether A.R.S. 23-1031 applied retroactively to two injured workers who had been awarded permanent partial disability benefits and were later incarcerated for crimes they had committed before the statute's effective date.
Although the court decided that the statute was substantive, rather than procedural, because it "functions substantively to redefine, regulate, or even eliminate a claimant's legal authorization to receive benefits," 198 Ariz. 467, P15, 11 P.3d 1006, P15, the court recognized that even "a substantive legal right may be subject to retroactive impairment before it becomes a vested right." 198 Ariz. 467 at P16.