Csizmadia v. Natl peo/the Mint, 1 CA-IC 15-0059

Matthew Csizmadia injured his left knee on Sept. 22, 2012 while working as a door host in Arizona; he continued working that shift and sought medical care a few days later.
He moved to New Jersey about 5–6 days after the injury without prior written approval from the Industrial Commission of Arizona (ICA); he later requested permission on Aug. 30, 2013 and the ICA approved that request retroactively to that date only.
Employer’s carrier accepted the claim but concluded no benefits were due; formal hearings followed and the ALJ issued an award covering medical/surgical/hospital benefits from Sept. 22, 2012 through Apr. 13, 2014, minus the unapproved absence period (Sept. 22, 2012–Aug. 30, 2013).
The ALJ denied any total temporary or temporary partial compensation and concluded the industrial injury produced no permanent impairment to the left knee.
Medical testimony conflicted: claimant’s treating physician (Dr. Greenberg) said claimant had persistent knee laxity and was slow to respond to treatment but was at maximum medical improvement by July 2014; ICA’s expert (Dr. Carter) found no objective basis tying ongoing symptoms to the industrial event and no need for further treatment.
The Court of Appeals affirmed the ALJ, deferring to the ALJ’s credibility determinations and concluding benefits were properly suspended during the unapproved out‑of‑state absence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ICA erred in terminating benefits/declaring claimant medically stationary	Csizmadia: ongoing treatment and additional impairments related to the industrial injury mean benefits should continue	ICA/Employer: medical evidence (Dr. Carter) shows no causal link, no permanent impairment, and no need for further treatment	Held for ICA: ALJ reasonably credited Dr. Carter; termination affirmed
Whether medical benefits should have been paid for care obtained while claimant lived in NJ without ICA approval	Csizmadia: seeks coverage for treatment during the out‑of‑state period because treatment continued	ICA/Employer: A.R.S. § 23‑1071 prohibits leaving Arizona >2 weeks without written approval; forfeiture applies to unapproved period	Held for ICA: benefits properly suspended from departure to Aug. 30, 2013 (retroactive approval could not cure earlier forfeiture)

Lane v. Indus. Comm’n, 218 Ariz. 44 (App. 2008) (ALJ factual findings deferred to; legal questions reviewed de novo)
Ortega v. Indus. Comm’n, 121 Ariz. 554 (App. 1979) (ICA not required to continue benefits absent proof of permanent disability related to industrial incident)
Lawler v. Indus. Comm’n, 24 Ariz. App. 282 (App. 1975) (claimant bears burden to prove causal relation and that condition is not medically stationary)
Malinski v. Indus. Comm’n, 103 Ariz. 213 (1968) (ALJ is sole judge of witness credibility and resolves conflicting medical evidence)
Waxler v. Indus. Comm’n, 116 Ariz. 213 (App. 1977) (courts decline to create exceptions to A.R.S. § 23‑1071 leaving‑state rule)
Cont’l Cas. Co. v. Indus. Comm’n, 113 Ariz. 116 (1976) (statute does not allow retroactive cure of an unapproved departure prior to filing for permission)