Ariz. Rev. Stat. » Title 23
Arizona Revised Statutes

Ariz. Rev. Stat. § 23-1043.01 (2026)

Heartrelated and mental cases

✓ current as of May 2026
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A. A heart-related or perivascular injury, illness or death shall not be considered a personal injury by accident arising out of and in the course of employment and is not compensable pursuant to this chapter unless some injury, stress or exertion related to the employment was a substantial contributing cause of the heart-related or perivascular injury, illness or death.

B. A mental injury, illness or condition shall not be considered a personal injury by accident arising out of and in the course of employment and is not compensable pursuant to this chapter unless some unexpected, unusual or extraordinary stress related to the employment or some physical injury related to the employment was a substantial contributing cause of the mental injury, illness or condition.

C. If compensation is payable for a heart-related or perivascular injury, illness or death, or for a mental injury, illness or condition, the only employer liable is the employee's last employer in whose employment the requirements of subsection A or B are met.

Notes of Decisions
Cited in 43 cases (10 in the last 5 years), 1981–2026 · leading case: Phelps v. Indus. Com'n of Arizona, 747 P.2d 1200 (Ariz. 1987).
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Phelps v. Indus. Com'n of Arizona, 747 P.2d 1200 (Ariz. 1987). · cites it 24× “QUESTION PRESENTED We must determine whether the testimony of the treating physican establishes a compensable heart-related injury meeting the requirements of A.R.S. § 23-1043.01(A). III. FACTS Petitioner severely fractured his left leg in seven places within the scope and…”
Toto v. Indus. Com'n of Arizona, 698 P.2d 753 (Ariz. Ct. App. 1985). · cites it 26× “The first is whether A.R.S. § 23-1043.01(B) violates either the equal protection clause of the United States Constitution or the Arizona Constitution’s prohibition against special laws.”
Grammatico v. Indus. Comm'n, 90 P.3d 211 (Ariz. Ct. App. 2004). · cites it 12× “The ALJ ruled that the claimant had failed to meet her burden under A.R.S. § 23-1043.01(A) (1995), which provided, in relevant part, that "[a] heart-related or perivascular injury, illness or death shall not be considered a personal injury by accident arising out of and in the…”
Murphy v. Indus. Com'n of Arizona, 774 P.2d 221 (Ariz. 1989). · cites it 18× “The administrative law judge held that A.R.S. § 23-1043.01(B) governed and denied the claim.”
Aguiar v. Indus. Com'n of Arizona, 797 P.2d 711 (Ariz. Ct. App. 1990). · cites it 26× “Her argument is based on A.R.S. § 23-1043.01 (1980). Compensability for Heart Illness In 1980, the Arizona Legislature enacted a statute relating to the compensability of “heart-related and mental cases.”
Ford v. Revlon, Inc., 734 P.2d 580 (Ariz. 1987). · cites it 4× “A.R.S. § 23-1043.01(B) sets forth the limiting standard for compensation under the statute for physiological injury.”
Lapare v. Indus. Com'n of Ariz., 742 P.2d 819 (Ariz. Ct. App. 1987). · cites it 12× “Following administrative review, claimant filed this special action raising two issues: 1. Was his psychotic episode a personal injury by accident arising out of and in the course of his employment within the meaning of A.”
Findley v. Indus. Com'n of Arizona, 660 P.2d 874 (Ariz. Ct. App. 1983). · cites it 10× “A.R.S. § 23-1043.01(B) which governs the compensability of mental injuries, states: B.”
T.W.M. Custom Framing v. Indus. Comm'n, 6 P.3d 745 (Ariz. Ct. App. 2000). · cites it 8× “section 23-1043.01 (1995), the statute at issue.”
Skyview Cooling Co. v. Indus. Com'n of Ariz., 691 P.2d 320 (Ariz. Ct. App. 1984). · cites it 10× “§ 23-1043.01 A. states: A heart-related or perivascular injury, illness or death shall not be considered a personal injury by accident arising out of and in the course of the employment and is not compensable pursuant to this chapter unless some injury, stress or exertion…”
Dugan v. Am. Express Travel Related Servs. Co., 912 P.2d 1322 (Ariz. Ct. App. 1995). · cites it 9× “section 23-1043.01 or by concluding that the facts overcame the presumption that heart-related injuries are not com-pensable.”
Barnes v. Indus. Comm'n, 750 P.2d 1382 (Ariz. Ct. App. 1988). · cites it 7× “Second, Fireman preceded the amendment embraced in A.R.S. § 23-1043.01 which specifically requires the stress not only be “unexpected, unusual or extraordinary”, but also that it be “related to the employment.”
Show all 43 citing cases →
— Ariz. Rev. Stat. § 23-1043.01(A) — 9 cases
Phelps v. Indus. Com'n of Arizona, 747 P.2d 1200 (Ariz. 1987). “QUESTION PRESENTED We must determine whether the testimony of the treating physican establishes a compensable heart-related injury meeting the requirements of A.R.S. § 23-1043.01(A). III. FACTS Petitioner severely fractured his left leg in seven places within the scope and…”
Grammatico v. Indus. Comm'n, 90 P.3d 211 (Ariz. Ct. App. 2004). “The ALJ ruled that the claimant had failed to meet her burden under A.R.S. § 23-1043.01(A) (1995), which provided, in relevant part, that "[a] heart-related or perivascular injury, illness or death shall not be considered a personal injury by accident arising out of and in the…”
Aguiar v. Indus. Com'n of Arizona, 797 P.2d 711 (Ariz. Ct. App. 1990). “Her argument is based on A.R.S. § 23-1043.01 (1980). Compensability for Heart Illness In 1980, the Arizona Legislature enacted a statute relating to the compensability of “heart-related and mental cases.”
Skyview Cooling Co. v. Indus. Com'n of Ariz., 691 P.2d 320 (Ariz. Ct. App. 1984). “§ 23-1043.01 A. states: A heart-related or perivascular injury, illness or death shall not be considered a personal injury by accident arising out of and in the course of the employment and is not compensable pursuant to this chapter unless some injury, stress or exertion…”
Dugan v. Am. Express Travel Related Servs. Co., 912 P.2d 1322 (Ariz. Ct. App. 1995). “section 23-1043.01 or by concluding that the facts overcame the presumption that heart-related injuries are not com-pensable.”
— Ariz. Rev. Stat. § 23-1043.01(B) — 28 cases
Toto v. Indus. Com'n of Arizona, 698 P.2d 753 (Ariz. Ct. App. 1985). “The first is whether A.R.S. § 23-1043.01(B) violates either the equal protection clause of the United States Constitution or the Arizona Constitution’s prohibition against special laws.”
Murphy v. Indus. Com'n of Arizona, 774 P.2d 221 (Ariz. 1989). “The administrative law judge held that A.R.S. § 23-1043.01(B) governed and denied the claim.”
Ford v. Revlon, Inc., 734 P.2d 580 (Ariz. 1987). “A.R.S. § 23-1043.01(B) sets forth the limiting standard for compensation under the statute for physiological injury.”
Lapare v. Indus. Com'n of Ariz., 742 P.2d 819 (Ariz. Ct. App. 1987). “Following administrative review, claimant filed this special action raising two issues: 1. Was his psychotic episode a personal injury by accident arising out of and in the course of his employment within the meaning of A.”
Findley v. Indus. Com'n of Arizona, 660 P.2d 874 (Ariz. Ct. App. 1983). “A.R.S. § 23-1043.01(B) which governs the compensability of mental injuries, states: B.”
— Ariz. Rev. Stat. § 23-1043.01(B)(1995) — 1 case
Harvest v. Craig, 48 P.3d 479 (Ariz. Ct. App. 2002).
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