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← 21 Ariz. App. 409 - Colvert v. Industrial Commission

21 Ariz. App. 409 - Colvert v. Industrial Commission’s Empirical Analysis

1974

Citation profile

31
cited by 31 later decisions
5
states following
September 2007
most recently cited

31 state decisions

How this case has been cited

Cited by 31 later decisions — most recently September 2007 · most notably Circle K Store 1131 v. Industrial Commission (1990), 10 Kan. App. 2d 501 - Springston v. IML Freight, Inc. (1985)

31 state decisions

1201974198019902000decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

Relationships

Relies on Peter Kiewit Sons' Co. v. Industrial Commission · 38 Cal. 2d 659 - State Compensation Insurance Fund v. Industrial Accident Commission · 49 N.J. Super. 60 - Crotty v. Driver Harris Co. · Crilly v. Ballou · Petro v. Martin Baking Co.

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Arizona’s workmen’s compensation laws were enacted to provide the workman with compensation for injuries arising out of and in the course of his employment. A.R.S. § 23-1021. The concept of fault and other common law doctrine based on fault have been eliminated in the employment setting. To adopt the aggressor rule defense would interject back into the workmen’s compensation laws such a fault concept. We therefore hold that where injuries are received as a result of a work related disagreement, the injuries arose out of and in the course of employment and are thus, by statute, compensable. We further hold that given the work-related assault, it is immaterial as to who was the aggressor for to base a defense on such a distinction would be to interject a fault concept into the workmen’s compensation laws, which concept is completely foreign to the purpose and intent of these laws.”
    1 later decision quote this exact passage
  2. “[I]t is universally agreed that if the assault grew out of an argument over the performance of the work, the possession of the tools or equipment used in the work, delivery of a paycheck, quitting work, trying to act as a peacemaker between quarreling employees, and the like, the assault is compensable.”
    1 later decision quote this exact passage
  3. “‘ . . . [Ajssaults by co-workers are compensable as long as they are not motivated by personal vengeance stemming from contract with the employee outside of the employment.” Col vert v. Industrial Commission, supra, 21 Ariz. App. 411 , 520 P.2d at 324 .”
    1 later decision quote this exact passage

How this case has been treated — in progress

Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.