Ibarra v. Indus. Comm'n of Ariz.

McMURDIE, Judge:

*1116¶ 1 This is a special action review of an Industrial Commission of Arizona award and decision upon review for a non-compensable claim. The issues raised by the claimant can be summarized as whether the physical assault that caused Carlos Ibarra's injuries "arose out of" his employment. We hold: (1) an assault is caused by the relations and conditions of the employment (the "friction and strain" of the employment) when the claimant and the other party to the assault have no personal contact outside of the employment, regardless of whether other job-related factors exist; and…