Montgomery v. Industrial Com'n of Arizona

OPINION

CONTRERAS, Presiding Judge.

This is a special action review of an Arizona Industrial Commission award denying compensability for Lyme disease. Four issues are presented on review: (1) whether the Administrative Law Judge erred by finding that the commonalty rule precluded compensability; (2) whether the positional risk doctrine mandated compensability; (3) whether the quantum theory of work-connection precluded compensability; and (4) whether the petitioner employee’s (“claimant’s”) injury constituted an occupational disease. We conclude that the Ad ministrative Law Judge erroneously…