Carvana LLC v. Fielder - Memorandum Decision - Arizona Court of Appeals - May 29, 2025

Christopher S. Norton, Esq.
Jul 5
2 min read

Facts: Luke Fielder, a technician at Carvana LLC, claimed he sustained a lower back injury while replacing a 50-pound car battery between May 8 and May 12, 2023. He initially attributed his pain to a kidney stone and continued working despite worsening symptoms. Medical evaluations later revealed advanced degenerative disc disease and disc herniation, which a doctor linked to a lifting injury at work. Fielder reported the injury as work-related on May 29, 2023. Carvana denied the claim, arguing the injury was not work-related and was reported late. The Industrial Commission of Arizona (ICA) ruled in favor of Fielder, finding his injury compensable. Carvana appealed the decision.

Issue(s):

Was Fielder’s lower back injury work-related?
Did Fielder fail to timely report the injury, thereby precluding benefits?

Holding: The Arizona Court of Appeals affirmed the ICA’s decision, finding substantial evidence supported the award. The court deferred to the Administrative Law Judge’s (ALJ) credibility determinations and factual findings, which concluded that Fielder’s injury was work-related and timely reported once he became aware of its cause.

Key Takeaways:

Credibility of Testimony: The court deferred to the ALJ’s assessment of Fielder’s credibility, which was pivotal in determining the injury’s work-related nature despite conflicting evidence from co-workers.
Timely Reporting: The court upheld the ALJ’s finding that Fielder reported the injury promptly after learning it was work-related, satisfying reporting requirements.
Standard of Review: The court emphasized its role in deferring to the ALJ’s factual findings and resolving conflicts in evidence, affirming the decision as long as a reasonable theory of evidence supports it.
No Debatable Issues: Carvana failed to present debatable issues on appeal, and Fielder’s failure to file an answering brief did not constitute a confession of error.