Cornelson v. Industrial Commission

OPINION

NOYES, Judge.

¶ 1 This is a Rule 10 special action review of a consolidated Industrial Commission of Arizona award and decision upon review denying petitions to reopen 1987 and 1989 claims for right knee injuries. We discuss and decide two issues: (1) whether the clo*270sure of the 1989 claim with a scheduled disability was void under Roseberry v. Industrial Commission, 113 Ariz. 66, 546 P.2d 802 (1976), and (2) whether, when petitioning to reopen after uncontested denials of prior petitions to reopen, proof of actual post-denial change of condition is required under Phoenix Cotton Pickery…