Arizona Revised Statutes

Ariz. Rev. Stat. § 23-1045 (2026)

Compensation for total disability; permanent total disability defined

✓ current as of May 2026
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23-1045. Compensation for total disability; permanent total disability defined

A. For temporary total disability the following compensation shall be paid:

1. Compensation of sixty-six and two-thirds percent of the average monthly wage shall be paid during the period of disability.

2. If there are persons dependent for support on the employee, compensation shall be paid as provided in this section, with an additional allowance of $100 per month for such dependents during the period of disability. The additional allowance shall not be based on a per capita number of dependents but shall reflect a total monthly benefit increase of exactly $100.

B. For permanent total disability, compensation of sixty-six and two-thirds percent of the average monthly wage shall be paid during the life of the injured person.

C. In the absence of proof to the contrary, disability shall be deemed total and permanent if caused by:

1. The total and permanent loss of sight of both eyes.

2. The loss by separation of both feet.

3. The loss by separation of both hands.

4. An injury to the spine resulting in permanent and complete paralysis of both legs or both arms, or one leg and one arm.

5. An injury to the skull resulting in incurable imbecility or insanity.

6. The loss by separation of one hand and one foot.

D. The enumeration in this section is not exclusive, and in all other cases permanent total disability shall be determined in accordance with the facts and in accordance with section 23-1047.

Notes of Decisions
Cited in 48 cases, 1959–2015 · leading case: Allen v. Indus. Comm'n, 347 P.2d 710 (Ariz. 1959).
Allen v. Indus. Comm'n, 347 P.2d 710 (Ariz. 1959). · cites it 10× “A permanent total disability is compensated at 65% of the average monthly wages, paid during the lifetime of the injured em *60 ployee, A.R.S. § 23-1045, subd. B. Certain disabilities are deemed total and permanent, in the absence of proof to the contrary; such as, loss of sight…”
State Comp. Fund v. Cramer, 474 P.2d 462 (Ariz. Ct. App. 1970). · cites it 16× “Under the provisions of A.R.S. § 23-1045, subsec. C, in the absence of proof to the contrary, the respondent-employee’s loss by separation of one hand and one foot is deemed to constitute permanent and total disability.”
Padilla v. Indus. Comm'n, 546 P.2d 1135 (Ariz. 1976). · cites it 5× “A.R.S. § 23-1045 (A) reads, in its pertinent part: “For temporary total disability the following compensation shall be paid: ****** 2.”
Padilla v. Indus. Comm'n, 535 P.2d 634 (Ariz. Ct. App. 1975). · cites it 15× “The point is that the legislature at the time it enacted § 23-1045 was not unaware of the situation of families with two working parents.”
Bergstresser v. Indus. Comm'n, 474 P.2d 450 (Ariz. Ct. App. 1970). · cites it 12× “The sole issue in this Workmen’s Compensation proceeding is whether, under the *92 statutory law as it existed prior to January 1, 1969, an injured workman awarded temporary total disability benefits at 65% of average monthly wage is entitled under the terms of A.R.S. § 23-1045,…”
Van Horn v. Indus. Comm'n, 523 P.2d 783 (Ariz. 1974). · cites it 8× “Accordingly, the claim is barred for failure to file written notice with the Commission *89 within one year from the date the injury became manifest, unless the employer commenced payments under the provisions of A.”
Linda Bell v. Ica/ Maricopa Cty/ Pinnacle Risk, 341 P.3d 1149 (Ariz. 2015). · cites it 2× “§ 23-1044(A) and temporary total disability (“TTD”) under A.R.S. § 23-1045(A). We further hold that § 23-1062(B) does not require proof of an initial period of TTD, but does require proof of seven consecutive days of some type of work-related disability before an injured…”
State Comp. Fund v. Harris, 545 P.2d 971 (Ariz. Ct. App. 1976). · cites it 4× “Harris, was left with a 100% loss of earning capacity, and that *11 he is entitled to benefits persuant to A.R.S. § 23-1045. The question before us is whether those benefits should be apportioned between the carrier and the Special Fund.”
Mannel v. Indus. Com'n of Arizona, 688 P.2d 1045 (Ariz. Ct. App. 1984). · cites it 2× “A.R.S. § 23-1045(B), A.R.S. § 23-1046. The credit balance was then approximately $79,000.”
W.F. Dunn, Sr. & Son v. Indus. Comm'n, 773 P.2d 241 (Ariz. Ct. App. 1989). · cites it 3× “Realistically Available Employment A.R.S. § 23-1045(D) governs compensation of non-presumptive permanent total disability.”
Inspiration Consol. Copper Co. v. Indus. Comm'n, 625 P.2d 351 (Ariz. Ct. App. 1981). · cites it 6× “” Petitioners further rely upon the wording of A.R.S. § 23-1045(A), which limits benefits “during the period of disability.”
Colorado River Inn v. Indus. Comm'n, 567 P.2d 343 (Ariz. Ct. App. 1977). · cites it 4× “However, the court held that this same doctor’s testimony concerning the claimant’s present condition could be properly considered in determining whether his condition was stationary and the reopening closed with a no disability finding.”
— Ariz. Rev. Stat. § 23-1045(A) — 9 cases
Linda Bell v. Ica/ Maricopa Cty/ Pinnacle Risk, 341 P.3d 1149 (Ariz. 2015). “§ 23-1044(A) and temporary total disability (“TTD”) under A.R.S. § 23-1045(A). We further hold that § 23-1062(B) does not require proof of an initial period of TTD, but does require proof of seven consecutive days of some type of work-related disability before an injured…”
Padilla v. Indus. Comm'n, 546 P.2d 1135 (Ariz. 1976). “A.R.S. § 23-1045 (A) reads, in its pertinent part: “For temporary total disability the following compensation shall be paid: ****** 2.”
Inspiration Consol. Copper Co. v. Indus. Comm'n, 625 P.2d 351 (Ariz. Ct. App. 1981). “” Petitioners further rely upon the wording of A.R.S. § 23-1045(A), which limits benefits “during the period of disability.”
Madrid v. Indus. Com'n of Arizona, 875 P.2d 839 (Ariz. Ct. App. 1994).
— Ariz. Rev. Stat. § 23-1045(A)(1) — 1 case
Howard P. Foley Co. v. Indus. Comm'n, 729 P.2d 326 (Ariz. Ct. App. 1986).
— Ariz. Rev. Stat. § 23-1045(A)(2) — 2 cases
Padilla v. Indus. Comm'n, 535 P.2d 634 (Ariz. Ct. App. 1975). “The point is that the legislature at the time it enacted § 23-1045 was not unaware of the situation of families with two working parents.”
Rico v. Indus. Comm'n, 846 P.2d 157 (Ariz. Ct. App. 1992).
— Ariz. Rev. Stat. § 23-1045(B) — 4 cases
Mannel v. Indus. Com'n of Arizona, 688 P.2d 1045 (Ariz. Ct. App. 1984). “A.R.S. § 23-1045(B), A.R.S. § 23-1046. The credit balance was then approximately $79,000.”
Inspiration Consol. Copper Co. v. Indus. Comm'n, 625 P.2d 351 (Ariz. Ct. App. 1981). “” Petitioners further rely upon the wording of A.R.S. § 23-1045(A), which limits benefits “during the period of disability.”
Marsh Aviation of Marana v. Indus. Comm'n, 634 P.2d 981 (Ariz. Ct. App. 1981).
Tipton v. Indus. Comm'n, 734 P.2d 1036 (Ariz. Ct. App. 1987).
— Ariz. Rev. Stat. § 23-1045(D) — 1 case
W.F. Dunn, Sr. & Son v. Indus. Comm'n, 773 P.2d 241 (Ariz. Ct. App. 1989). “Realistically Available Employment A.R.S. § 23-1045(D) governs compensation of non-presumptive permanent total disability.”
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