Hardware Mutual Casualty Company v. Industrial Commission

In Hardware Mutual Casualty Company v. Industrial Commission, 17 Ariz. App. 7, 9-10, 494 P.2d 1353, 1355-56 (1972) the Court listed the three phases of a worker's injury as follows: (1) a period of temporary total physical incapacity during which time his injuries would prohibit him from working at all; (2) a period of temporary partial incapacity during which time his ability to work, through treatment and convalescence, has increased to a point where he may engage in some activity but he has not progressed to the stage that he no longer needs medical treatment; and; (3) his condition has become medically stationary, that is, his condition cannot be medically improved to increase his activities and hence increase his earning capacity. Based upon this three stage physical development, an injured workman may be compensated correspondingly for: (1) temporary total disability (A.R.S. 23-1045, subdivision A); (2) temporary partial disability (A.R.S. 23-1044, subdivision. A); (3) permanent total or partial disability (A.R.S. 23-1044, subdivision. B, C; 23-1045, subdivision B).