Printz v. Greathearts/Pacific - Memorandum Decision - Arizona Court of Appeals - August 5, 2025

Christopher S. Norton, Esq.
Aug 7
2 min read

Printz v. Greathearts/Pacific - Memorandum Decision - Arizona Court of Appeals - August 5, 2025

Facts: Jennifer Printz, a teacher at Scottsdale Preparatory Academy, filed a workers’ compensation claim in October 2022, alleging that mold exposure at her workplace caused her sinus infection. The claim was denied by Pacific Compensation Insurance Company, and Printz failed to request a hearing within the 90-day statutory period. In June 2023, she filed a second claim for the same injury, which was also denied. This time, she requested a hearing, but the Industrial Commission of Arizona (ICA) ruled that her second claim was barred because she did not timely challenge the denial of her first claim. Printz sought judicial review of the ICA’s decision.

Issue(s):

Does the failure to request a hearing within 90 days of a denied workers’ compensation claim preclude a claimant from filing a second claim for the same injury?
Can a claimant argue that the first claim was a "nullity" due to a lack of complete medical evidence at the time of filing?

Holding: The Arizona Court of Appeals affirmed the ICA’s decision, holding that:

Under A.R.S. § 23-947(A), a claimant must request a hearing within 90 days of a claim denial, or the denial becomes final and binding.
Printz’s argument that her first claim was a "nullity" was rejected because she recognized the nature, seriousness, and probable work-related cause of her injury when she filed the first claim.

Key Takeaways:

A workers’ compensation claim denial becomes final and res judicata if the claimant does not request a hearing within 90 days, as required by A.R.S. § 23-947(A).
Filing a second claim for the same injury does not reset or extend the statutory deadline for requesting a hearing.
The statute of limitations for filing a claim begins when the injury becomes manifest, but once a claim is filed, the claimant must adhere to the procedural deadlines.
The court distinguished this case from Henry v. Industrial Commission, emphasizing that Printz’s injury was manifest when she filed her first claim, and her failure to act within the statutory timeframe barred further action.

URL to Read Full Decision: IC24-0058 Printz (07292025) Final.pdf