In Rockwell Collins, Old Republic Insurance Co. v. Industrial Commission of Arizona, Bryan The claimant, the Arizona Court of Appeals affirmed an award of the Industrial Commission of Arizona (ICA) that allowed the claimant to continue receiving workers' compensation benefits for a work-related respiratory condition.
The claimant had worked for Rockwell Collins for many years and was regularly exposed to industrial chemicals, including paints, solvents, primers, and other hazardous substances used in aircraft manufacturing. His workers' compensation claim was accepted, but several years later the employer's independent medical examiner concluded that any work-related condition had resolved and that the claimant was medically stationary. Based on that opinion, the employer and its insurance carrier closed the claim.
The claimant challenged the closure before the ICA, where both sides presented conflicting medical evidence. The claimant's treating pulmonary specialist testified that he continued to suffer from asthma and obstructive lung disease caused by his workplace chemical exposure and that he required ongoing medical treatment. The employer's medical experts disagreed, opining that the claimant no longer had a work-related pulmonary condition and that no further treatment was necessary.
After considering the testimony, the ALJ found the claimant's medical expert more persuasive and ruled that the claimant was not medically stationary, that his respiratory condition remained industrially related, and that he was entitled to continued workers' compensation benefits.
On appeal, Respondents argued that the claimant's physician did not provide an unequivocal medical opinion and that the ALJ therefore should not have relied on his testimony. The Arizona Court of Appeals rejected that argument, holding that the physician's testimony was sufficiently definite to create a genuine conflict in the medical evidence. The court explained that a medical expert is not required to use specific words or provide a formal diagnosis in any particular format so long as the opinion is expressed to a reasonable degree of medical certainty. Because it is the ALJ's responsibility to resolve conflicts in medical testimony, and because the ALJ's decision was supported by reasonable evidence, the court affirmed the ICA's award.
The decision reinforces the principle that appellate courts will defer to an ALJ's credibility determinations and weighing of conflicting medical evidence unless those findings are wholly unreasonable.
Rockwell Collins v. Indus. Comm'n of Ariz., No. 2 CA-IC 2025-0011 (Ariz. Ct. App. Mar. 31, 2026)
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