Hendrickson v. INDUSTRIAL COM'N OF ARIZONA

OPINION

McGREGOR, Vice Chief Justice.

¶ 1 We granted review to consider again the effect of a workers’ compensation claimant’s failure to obtain written approval for settlement of an action against a third party. We hold that, under the facts of this ease, the forfeiture rule of Hornback v. Industrial Commission, 106 Ariz. 216, 474 P.2d 807 (1970), does not apply. Instead, we apply the equitable approach of Bohn v. Industrial Commission, 196 Ariz. 424, 999 P.2d 180 (2000).

i.

¶ 2 In 1982, while working as a flight attendant for Continental Airlines, Sherry Hendrickson sustained an injury to both…