Grammatico v. Indus. Comm'n
In Grammatico v. Indus. Comm'n, 208 Ariz. 10, P6, 90 P.3d 211, 213 (App. 2004), the Arizona Supreme Court stated article XVIII, 8 "addresses legal causation" and determined "the legislature may not define legal causation in a way that conflicts with that section because the legislature 'cannot enact laws which will supersede constitutional provisions adopted by the people.'" 211 Ariz. 67, PP19, 21, 117 P.3d at 790, 791.
But the court also stated, "Article 18, Section 8 does not limit the legislature's power to enact legislation affecting medical causation," id. P 20; therefore, "the legislature has some latitude to establish the requisite medical causation for workers' compensation recovery." Id. P 21.