Carr v. Industrial Commission
In Carr v. Industrial Commission, 197 Ariz. 164, 3 P.3d 1084 (App. 1999), the claimant lived in a rural area outside of Seligman, Arizona. 197 Ariz. at 165,2, 3 P.3d at 1085.
The closest available medical treatment was in Flagstaff, Arizona, a 230 mile round trip from his home. Id. at 165-66,4, 3 P.3d at 1085-86.
The Court concluded that without payment of travel expenses, the claimant effectively was precluded from receiving the medical benefits to which he was entitled under the Arizona Workers' Compensation Act. Id. at 167,12, 3 P.3d at 1087.
For that reason, the Court held "that an injured worker who must travel outside the area in which he or she resides to receive treatment is entitled to reimbursement for travel expenses." Id.