Schnatzmeyer v. Industrial Commission
In Schnatzmeyer v. Industrial Commission, 77 Ariz. 266, 269, 270 P.2d 794, 796 (1954), the Arizona Supreme Court, in reviewing the Industrial Commission's determination that a claimant had made insufficient effort to secure employment because he did not seek work outside the area of Kingman, stated that a claimant should not be required to "abandon his established home and, at an expense he can ill afford, that he travel from state to state or community to community" in an effort to obtain employment.
In support thereof, the court quoted a Vermont case for the proposition that "there is incapacity for work when a man has a physical defect which makes his labor unsalable in any market reasonably accessible to him . . . ." Id.