written records requirement in Arizona

6 Arizona opinions name it 2 courts 1994–1998 0 in the last five years

The cases below were cited by Arizona courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

Case	Followed	Cited
Sea-Land Services v. Second Injury Fundgreen alaska · 1987 · cited in 3 Arizona opinions naming this issue, 1995–1996 2 sentences 1996Sea-Land Services, Inc. v. Second Injury Fund, 737 P.2d 793, 796 (Alaska 1987) (Compton, J., dissenting). 1996Sear-Land Services, Inc. v. Second Injury Fund, 737 P.2d 793, 796 (Alaska 1987) (Compton, J., dissenting).	3	3
Transporting Renew. Res. v. Indus. Com'ngreen arizctapp · 1996 · cited in 2 Arizona opinions naming this issue, 1997–1998 2 sentences 1998The clearest example that the written records requirement is only evidentiary in nature and the employer’s knowledge controls is Transporting Renewable Resources, in which the court of appeals held that the written records requirement was satisfied by stipulation even though there had been no written record at all. 185 Ariz. at 544-45, 917 P.2d at 273-74. 1998The clearest example that the written records requirement is only evidentiary in nature and the employer’s knowledge controls is Transporting Renewable Resources, in which the court of appeals held that the written records requirement was satisfied by stipulation even though there had been no written record at all. 185 Ariz. at 544-45, 917 P.2d at 273-74.	2	2
Country Wide Truck Service v. Industrial Commissiongreen arizctapp · 1994 · cited in 1 Arizona opinions naming this issue, 1998–1998 2 sentences 1998See, e.g., Country Wide, 181 Ariz. at 412 , 891 P.2d at 879 (“the inquiry should be whether the impairment is such that an employer who knew of it and its extent would more likely than not significantly consider it when making a decision to hire or retain the employee.”). 1998See, e.g., Country Wide, 181 Ariz. at 412 , 891 P.2d at 879 (“the inquiry should be whether the impairment is such that an employer who knew of it and its extent would more likely than not significantly consider it when making a decision to hire or retain the employee.”).	1	1
Arizona Bd. of Regents for and on Behalf of University of Arizona v. State Ex Rel. State, Public Safety Retirement Fund Manager Administratorgreen arizctapp · 1989 · cited in 1 Arizona opinions naming this issue, 1995–1995 2 sentences 1995Public Safety Retirement Fund Manager Adm’r, 160 Ariz. 150, 157 , 771 P.2d 880, 887 (App. 1989), the latter interpretation would defeat the purpose of the written records requirement: if the written record establishing employer knowledge does not precede the injury, then apportionment would always be available as soon as the employer acquires a written medical report, occasioned by the claim but also reporting preexisting impairments, 6 a result that would render the statutory requirements pointless. 1995Public Safety Retirement Fund Manager Adm’r, 160 Ariz. 150, 157 , 771 P.2d 880, 887 (App. 1989), the latter interpretation would defeat the purpose of the written records requirement: if the written record establishing employer knowledge does not precede the injury, then apportionment would always be available as soon as the employer acquires a written medical report, occasioned by the claim but also reporting preexisting impairments, 6 a result that would render the statutory requirements pointless.	1	1
Schuff Steel v. INDUSTRIAL COM'N OF ARIZ.green arizctapp · 1994 · cited in 1 Arizona opinions naming this issue, 1995–1995 2 sentences 1995Schuff Steel Co., 181 Ariz. at 446, 891 P.2d at 913 (“To interpret this requirement as Argonaut sug 368 gests, however, totally eviscerates the written records requirement.”); see also Walker v. City of Scottsdale, 163 Ariz. 206, 210 , 786 P.2d 1057, 1061 (App.1989) (court must give meaning to each component of statute so that no part of statute becomes void, inert, redundant, or trivial). 1995Schuff Steel Co., 181 Ariz. at 446, 891 P.2d at 913 (“To interpret this requirement as Argonaut sug 368 gests, however, totally eviscerates the written records requirement.”); see also Walker v. City of Scottsdale, 163 Ariz. 206, 210 , 786 P.2d 1057, 1061 (App.1989) (court must give meaning to each component of statute so that no part of statute becomes void, inert, redundant, or trivial).	1	1
Padilla v. Chavezgreen nmctapp · 1987 · cited in 1 Arizona opinions naming this issue, 1995–1995 2 sentences 1995See, e.g., Sea-Land Services, 737 P.2d at 795 & n. 2; Padilla v. Chavez, 105 N.M. 349, 351 , 732 P.2d 876, 878 (Ct.App.1987); U.S. Pipe & Foundry Co. v. Caraway, 546 S.W.2d 215, 218 (Tenn.1977); see also 2 Larson, supra, § 59.33.a (“Since the underlying policy extends to retention of the handicapped, manifestation [of the impairment] at any time prior to the final injury is sufficient.”) (emphasis added). 1995See, e.g., Sea-Land Services, 737 P.2d at 795 & n. 2; Padilla v. Chavez, 105 N.M. 349, 351 , 732 P.2d 876, 878 (Ct.App.1987); U.S. Pipe & Foundry Co. v. Caraway, 546 S.W.2d 215, 218 (Tenn.1977); see also 2 Larson, supra, § 59.33.a (“Since the underlying policy extends to retention of the handicapped, manifestation [of the impairment] at any time prior to the final injury is sufficient.”) (emphasis added).	1	1
U. S. Pipe & Foundry Co. v. Carawaygreen tenn · 1977 · cited in 1 Arizona opinions naming this issue, 1995–1995 1 sentence 1995See, e.g., Sea-Land Services, 737 P.2d at 795 & n. 2; Padilla v. Chavez, 105 N.M. 349, 351 , 732 P.2d 876, 878 (Ct.App.1987); U.S. Pipe & Foundry Co. v. Caraway, 546 S.W.2d 215, 218 (Tenn.1977); see also 2 Larson, supra, § 59.33.a (“Since the underlying policy extends to retention of the handicapped, manifestation [of the impairment] at any time prior to the final injury is sufficient.”) (emphasis added).	1	1
Walker v. City of Scottsdalegreen arizctapp · 1989 · cited in 1 Arizona opinions naming this issue, 1995–1995 2 sentences 1995Schuff Steel Co., 181 Ariz. at 446, 891 P.2d at 913 (“To interpret this requirement as Argonaut sug 368 gests, however, totally eviscerates the written records requirement.”); see also Walker v. City of Scottsdale, 163 Ariz. 206, 210 , 786 P.2d 1057, 1061 (App.1989) (court must give meaning to each component of statute so that no part of statute becomes void, inert, redundant, or trivial). 1995Schuff Steel Co., 181 Ariz. at 446, 891 P.2d at 913 (“To interpret this requirement as Argonaut sug 368 gests, however, totally eviscerates the written records requirement.”); see also Walker v. City of Scottsdale, 163 Ariz. 206, 210 , 786 P.2d 1057, 1061 (App.1989) (court must give meaning to each component of statute so that no part of statute becomes void, inert, redundant, or trivial).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Arizona. Read the followed side critically anyway.

Also cited on this issue (4)

Case	Cited	Years
Gilbane Co. v. Poulas green ri · 1990 2 sentences 1995Finally, Argonaut relies upon the reasoning of Gilbane Co. v. Poulas, 576 A.2d 1195 (R.I.1990), to support its position that the Model Act or a similar written records requirement may apply to an employer’s knowledge of permanent impairment acquired after the industrial injury. 1994To this end, it relies on Gilbane Co. v. Poulas, 576 A.2d 1195 (R.I.1990).	2	1994–1995
Special Fund Division v. Industrial Commission green arizctapp · 1997 2 sentences 1998Special Fund Div. (Burrell), 189 Ariz. at 162 , 939 P.2d at 795 . 1998Special Fund Div. (Burrell), 189 Ariz. at 162 , 939 P.2d at 795 .	1	1998–1998
Special Fund Division v. Industrial Commission green arizctapp · 1995 2 sentences 1997In Special Fund Div. (Pete King), the employer obtained written records after the employee suffered an industrial injury. 184 Ariz. at 364 , 909 P.2d at 431 . 1997In Special Fund Div. (Pete King), the employer obtained written records after the employee suffered an industrial injury. 184 Ariz. at 364 , 909 P.2d at 431 .	1	1997–1997
Salt River Project v. Industrial Commission green arizctapp · 1992 2 sentences 1995Salt River Project v. Industrial Comm'n, 172 Ariz. 477 , 480 & n. 4, 837 P.2d 1212 , 1215 & n. 4 (App.1992). 4 . 1995Salt River Project v. Industrial Comm'n, 172 Ariz. 477 , 480 & n. 4, 837 P.2d 1212 , 1215 & n. 4 (App.1992). 4 .	1	1995–1995

Statutes the citing opinions construe

AZ § Ariz. Rev. Stat. § 23-1065 (6)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

AZ 6 (1994–1998) NE 2 (1998–2006) AK 2 (1988–2008)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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