Laker v. Indus. Comm'n
In Laker v. Indus. Comm'n, 139 Ariz. 459, 462, 679 P.2d 105, 108 (App. 1984), the claimant asserted that the carrier failed to prove that "merit raises" paid to all employees were not disguised cost of living increases. Laker, 139 Ariz. at 463, 679 P.2d at 109.
Because the claimant, not the carrier, had the burden of proof and "merit raises based on continued satisfactory performance or longevity" realistically reflect earning capacity, the court rejected the claimant's assertion. Id.