East v. Industrial Commission

In East v. Industrial Commission, 137 Ariz. 315, 317, 670 P.2d 420, 422 (App. 1983), the Court concluded that an attenuated causal connection may not support compensation. In East, the claimant sustained two nonindustrial shoulder injuries before a third compensable industrial shoulder injury. Id. at 316, 670 P.2d at 421. The shoulder was surgically stabilized, and after the claim was closed, the claimant sustained another nonindustrial shoulder injury and unsuccessfully petitioned to reopen. Id. at 316-317, 670 P.2d at 421-22. The Court affirmed the denial of reopening and observed that, even if the medical testimony had supported a predisposition to reinjury, causation was too attenuated. Id. at 317, 670 P.2d at 422.