Joplin v. Industrial Commission

In Joplin v. Industrial Commission, 175 Ariz. 524, 858 P.2d 669 (App. 1993) the Court stated that an injury sustained by a claimant in an automobile accident while traveling for medical treatment for an earlier industrial injury is compensable. The claimant sustained an industrial injury to his left foot, and his treating physician recommended physical therapy. 175 Ariz. at 525, 858 P.2d at 670. To receive this treatment, Joplin commuted from his home to a hospital. Id. During one of his commutes, he sustained injuries in an automobile accident while driving home several hours after his physical therapy session had ended. Id. He filed a workers' compensation claim for these injuries, alleging they were a compensable consequence of the industrial injury. Id. The court concluded that accidental injuries sustained during travel to obtain medical treatment for an industrial injury should be compensable. 175 Ariz. at 527, 858 P.2d at 672. In reaching this conclusion, the court recognized that although our supreme court has denied coverage for travel to an independent medical examination, Whitington v. Industrial Comm'n, the court has never determined that travel for treatment is not covered. The A.L.J. concluded that Whitington did not apply to travel for treatment because the supreme court distinguished travel for independent medical examinations from travel for treatment. Id. In Joplin, the court explained the rationale behind this distinction, in part, as follows. Under Arizona's Workers' Compensation Act, employers are required to furnish medical care to injured employees, and employees are similarly under a duty to submit to reasonable medical treatment. 175 Ariz. at 527, 858 P.2d at 672.