Horan v. Industrial Com'n of Arizona

OPINION

FIDEL, Judge.

In this review of an Industrial Commission award denying temporary disability benefits, we address three issues: (1)

whether an offer of proof is necessary to achieve review of an exclusion of evidence; (2) whether a neurologist may express an opinion concerning the etiology of a psychological condition; and (3) whether exclusion of the neurologist’s opinion was harmless error.

History

In December 1988, claimant injured her back at work. Respondent carrier’s agent (GAB) accepted compensability. Despite physical therapy, claimant continued to complain of pain. In February…