Jasso v. Industrial Commission of Arizona - Memorandum Decision - Arizona Court of Appeals - June 12, 2025

Facts: Cynthia Jasso, a McDonald’s employee, sustained injuries on November 18, 2023, when containers of liquid ice cream fell on her right hand, shoulder, arm, elbow, and head. ​ Her injury claim was accepted, and she received medical and compensation benefits. ​ On February 9, 2024, the respondent carrier closed her claim, stating there was no permanent impairment. ​ Jasso challenged the closure, arguing she required ongoing medical care and temporary disability benefits. ​ After a four-day evidentiary hearing, the administrative law judge (ALJ) awarded her temporary benefits through February 9, 2024, but found her injury medically stationary with no permanent disability. ​ Jasso requested a review, and the ALJ affirmed the decision. ​

Issue(s):

1. Did the ALJ err in determining Jasso’s injury was medically stationary with no permanent disability? ​

2. Did Jasso’s failure to comply with procedural rules affect her appeal? ​

   
   

Holding: The Arizona Court of Appeals affirmed the ALJ’s decision, finding no error in the determination that Jasso’s injury was medically stationary with no permanent disability. The court also held that Jasso’s failure to comply with procedural rules, including the lack of legal argument, citations to the record, and explanation of alleged errors, constituted a waiver of appellate review. ​

Key Takeaways:

1. Self-represented litigants are held to the same procedural standards as attorneys and must comply with applicable rules to preserve appellate review. ​

2. Appellants must provide clear legal arguments, citations to the record, and identify specific errors in the lower court’s decision. Failure to do so may result in waiver of appellate review. ​

3. The court will not reweigh evidence or conduct an independent review of the record to identify potential errors. ​

   
   

Read Full Decision: IC20250002memo.pdf