Wammack v. Industrial Commission

In Wammack v. Industrial Commission, 83 Ariz. 321, 320 P.2d 950 (1958), one of the award's findings merely stated that "full consideration" had been given to the factors set forth in A.R.S. 23-1044(D) for determining a loss of earning capacity and "to all of the facts and circumstances pertaining to the case." Wammack, 83 Ariz. at 325, 320 P.2d at 953. The court held that this finding did not indicate "what matters were given consideration in arriving at reduced earning capacity" and "how they influenced the ultimate award." As a result, the court adopted the following rule for an administrative agency's findings: They must be sufficiently "explicit to enable the reviewing court to review the decision intelligently and to ascertain whether the facts as found afford a reasonable basis for the decision or be sufficiently definite and certain to permit of judicial interpretation. "Id.