Thompson v. Youngs/Safety - Memorandum Decision - Arizona Court of Appeals - June 3, 2025

Facts: Adrian Thompson, an employee of Youngs Market Co. of Arizona, LLC, sustained a workplace injury in July 2021. ​ After initially denying compensability, the Industrial Commission of Arizona (ICA) found the injury compensable, and Thompson received benefits. ​ In February 2023, Youngs and its carrier, Safety National Casualty Corp., closed the claim with no permanent disability, which Thompson protested due to unpaid bills. ​ In June 2024, the parties reached a settlement agreement, under which Thompson received $1,076.91 for temporary disability benefits, mileage reimbursements, and medical bills. ​ Thompson signed a sworn statement affirming the settlement was in his best interest and free from duress, fraud, or coercion. ​ The ICA Administrative Law Judge (ALJ) approved the settlement, noting Thompson had 30 days to request administrative review. ​ Thompson later requested a "re-review" of the settlement, believing signing a waiver form would prevent reopening his claim. ​ The ALJ affirmed the settlement, clarifying the claim was not fully and finally settled and the waiver form did not affect future rights to reopen the claim. ​ Thompson then sought judicial review, arguing the settlement was inadequate and based on procedural and factual errors. ​

Issue(s):

1. Did the settlement agreement adequately reflect the severity of Thompson's injuries and ongoing medical needs? ​

2. Were procedural or factual errors present in the settlement process? ​

3. Did Thompson waive his arguments by failing to raise them during the ICA proceedings? ​

Holding: The Arizona Court of Appeals affirmed the ICA's approval of the settlement agreement. Thompson failed to preserve his arguments for appeal by not raising them during the ICA proceedings. ​ Even if not waived, the court found his arguments unpersuasive, as the record showed Thompson knowingly and voluntarily agreed to the settlement terms without coercion, fraud, or duress. ​

Key Takeaways:

1. Arguments not raised during ICA proceedings are considered waived on appeal unless exceptional circumstances apply. ​

2. Partial settlements in workers' compensation cases are permissible and governed by contract principles once approved by the ICA. ​

3. The ICA must find that a bona fide dispute exists, the claimant understands the settlement terms, and the agreement is free from coercion, fraud, or misrepresentation before approving a settlement. ​

4. Thompson's notarized statement and the ALJ's findings supported the validity of the settlement agreement. ​

Read Full Decision: 1 CA-IC 24-0046 Thompson v. Youngs-Safety.pdf