Tabler v. Industrial Com'n of Arizona

OPINION

GEMMILL, Judge.

¶ 1 May an oral compromise and settlement agreement be approved by the Industrial Commission of Arizona (ICA) and enforced against the employer and carrier, even though the claimant died before a written compromise and settlement agreement (“G & S”) was executed? We answer this question in the affirmative and set aside a decision upon review declining to approve a C & S.

Facts and Procedural History

¶ 2 On July 31, 2000, the attorneys for the parties orally agreed to settle Howard Tabler’s workers’ compensation claim as noncompensable for $55,000. Tabler’s attorney, Robert…