Medical Evidence Disconnects Ariz. Worker’s Carpal Tunnel from AutoZone Work

06 Nov, 2023 Frank Ferreri


Phoenix, AZ ( -- When a worker's wrist problems sent him into surgery, did he have enough medical evidence to establish a compensable injury?

According to the court in, Johnson v. Industrial Commission of Arizona, No. 1 CA-IC 23-0003 (Ariz. Ct. App. 10/31/23, unpublished) the worker's medical evidence did not create a link between his job and his carpal tunnel troubles.

An AutoZone employee was unloading a pallet of items, including truck rotors, when he felt his hands pop and numbness and tingling in his fingers. Over the next several days, the numbness and tingling worsened, leaving the employee "barely able" to use his hands.

About two months after the workplace incident, the employee received treatment for severe carpal tunnel syndrome and tendonitis, which culminated in carpal tunnel release surgeries on both of the employee's hands.

The employee filed a workers' compensation claim, which was denied. Before the case went to a hearing in front of an administrative law judge, an independent medical examination concluded that the employee's carpal tunnel syndrome and surgeries were unrelated to a work injury.

The ALJ issued an award finding that the employee had not proven, by a preponderance of the evidence, that he sustained a compensable industrial injury. After an administrative review, the ALJ affirmed the award, prompting the employee to take the case to court.

In Arizona, to arise out of employment, an injury must result from some risk of the employment or be incidental to the discharge of employment duties. Risks inherent in the physical condition of an employee are not compensable.

Additionally, regarding the evidence, if the work connection to an injury is not apparent to a nonspecialist, expert medical testimony is necessary to prove compensability. In this case, the two medical experts that testified opined that the employee's carpal tunnel syndrome and his need for carpal tunnel release surgery were not caused by his work unloading pallets at AutoZone.

As a result, the court upheld the ALJ's decision.

"Because [the employee] failed to show his injury arose of his employment, the ALJ did not err by finding his claim non-compensable," the court wrote.

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    About The Author

    • Frank Ferreri

      Frank Ferreri, M.A., J.D. covers workers' compensation legal issues. He has published books, articles, and other material on multiple areas of employment, insurance, and disability law. Frank received his master's degree from the University of South Florida and juris doctor from the University of Florida Levin College of Law.

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