Hughes v. Industrial Commission
In Hughes v. Industrial Commission, 188 Ariz. 150, 933 P.2d 1218 (App. 1996), the Court held that "other treatment" did not encompass child care services for purposes of benefits under A.R.S. 23-1062(A). 188 Ariz. at 153-54, 933 P.2d at 1221-22.
The claimant argued that "child care was reasonably required other treatment because it was necessitated by and necessary to treat her industrial injury." Id. at 153, 933 P.2d at 1221.
Applying the principle of ejusdem generis to A.R.S. 23-1062(A), the Court concluded that the statute did not extend to child care because it was not of the same type or class as the specifically enumerated services. Hughes, 188 Ariz. at 154, 933 P.2d at 1222.
The court reasoned that child care was a service "not generally considered medical treatment." Id.