Grammatico v. Industrial Commission: Invalidating Statutes Making Alcohol or Drug Use a Bar to Workers’ Compensation Claims in Arizona

In Grammatico, the Arizona Supreme Court invalidated two Arizona workers’ compensation statutes: section 23-1021(C), which required an employee who was under the influence of alcohol at the time of injury to prove the alcohol was not even a slight contributing cause of injury; and section 23-1021(D), which required an employee who fails a post-accident drug test for use of an illegal substance to prove the drug use did not at all contribute to injury.