Ball Mfg. v. Industrial Commission

*27OPINION

VOSS, Judge

This is a special action review of an industrial commission award for a compensable claim and finding of “special circumstances” justifying liability for medical treatment, including back surgery, despite lack of statutory notice to petitioner employer (Ball). The issues presented on review are: (1) whether respondent employee (claimant) satisfied his burden of medical proof; and, (2) whether petitioner carrier’s (Lumbermen’s) processing of an apparent no time loss claim constituted a “special circumstance” obviating the notice requirement of Ariz.Rev.Stat.Ann. (“A.R.S.”) §…