Stenz v. Industrial Commission

Chief Justice BALES,

opinion of the Court:

¶ 1 Although Arizona’s Workers’ Compensation Act does not mandate the payment of interest on benefits not timely paid, this Court has held that the general interest statute, A.R.S. § 44-1201, applies to workers’ compensation awards. Today we hold that death benefits under A.R.S. § 23-1046 are liquidated, and interest on them accrues from the time a carrier receives notice that a survivor has filed a claim with the Industrial Commission pursuant to A.R.S. § 23-1061(A).

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¶ 2 In 2005, Charles Stenz suffered an on-the-job injury for which he filed a claim…