Did Worker who Told Supervisor about ‘Burning’ Knees Properly Report Injury?

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An employer may be able to deny a workers’ compensation claim by showing that the employee never reported the injury. But what does reporting an injury entail? An Arizona case involving a worker whose knees “popped” while working sheds light on this topic.

On the morning of Aug. 19, 2021, the claimant heard his knees "pop" while working. By the afternoon, he told a co-worker his knees hurt. The co-worker later said that he could tell the claimant was having a hard time walking that day.

Before his shift ended, the claimant told his off-site supervisor he injured his knees. His left knee was "burning," he said. The supervisor sent an email to the company’s human resources department about the injury. The coworkers later said the claimant told the supervisor he hurt himself while working.

To collect workers’ compensation benefits, an employee must promptly report his work-related injury to his employer. Prompt reporting enables the employer to get medical care right away and obtain an immediate diagnosis. It also permits the employer to promptly investigate the circumstances of the injury.

Was the employer on notice of a work-related injury?

A. Yes. The fact that the supervisor contacted HR about the injury indicated that he thought it was work-related. That, along with the coworkers' statements showed that the claimant reported a work-related injury to the company.

B. No. There wasn’t evidence that he told his supervisor that his knees were hurting because of an accident at work. As far as the supervisor knew, he could have injured them at home.

If you selected A, you agreed with the court in Transact Campus v. Industrial Commission of Arizona, 1 CA-IC 25-0008 (Ariz. Ct. App. 12/10/25), which found sufficient evidence that the company was on notice of a work-related injury.

The court noted that the claimant reported his injury to his supervisor the same day. Also, two other people said the claimant told his supervisor that he was hurt while he was working.

The court acknowledged that an employee telling a supervisor he does not feel well or is in pain does not by itself serve as notice of the injury. This is because it doesn’t necessarily inform the employer that the injury is work-related. But in this case, there were other signs that the employer knew the injury occurred while at work: 1) the claimant told his supervisor he hurt his knees on the day it happened; 2) the supervisor emailed HR about the injury; and 3) coworkers said he told his supervisor he injured his knees while on the job.

“Thus, both [the claimant] and the supervisor believed the injury was work-related. This put Transact on notice,” the court said. It affirmed a decision that the claimant promptly reported his injury and that his claim was compensable.

Looking for cases from Arizona or the rest of the U.S. Find them on Simply Research.

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