Ramos v. Papa john's/farmers, 1 CA-IC 16-0027

On April 4, 2015, Ramos injured his right groin at work when two heavy boxes slipped and a box slid onto his right groin; he noticed a lump shortly thereafter and sought same‑day treatment.
His claim for workers' compensation was accepted but closed effective April 6, 2015; Ramos later filed a petition to reopen in September 2015.
Ramos testified to persistent and worsening pain radiating to his right testicle when lifting; he was the sole live witness at the ALJ hearing and submitted medical records and two independent medical examination (IME) reports.
December 2015 imaging showed a small subcutaneous hypoechoic mass; one IME (pain medicine) said the mass appeared unchanged and not a new condition; the surgeon IME agreed it was unchanged and unlikely caused by the industrial injury.
The ALJ denied reopening because Ramos offered only subjective pain complaints without objective change and failed to prove a new, additional, or previously undiscovered condition causally related to the industrial injury.
The Industrial Commission affirmed and Ramos sought special action review in the Court of Appeals, which affirmed the ICA decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether claim may be reopened for a new/additional/previously undiscovered condition	Ramos argued his pain increased and condition worsened since closure, warranting reopening	ICA/Employer argued medical evidence showed no objective change or new condition and no causal link to the industrial injury	Denied — Ramos failed to show a new/additional/previously undiscovered condition or objective change
Whether subjective pain alone can justify reopening	Ramos relied on his testimony about increased pain when lifting	ICA/Employer relied on statutes/case law requiring objective findings for reopening based on increased pain	Denied — subjective pain without objective physical change insufficient
Whether expert testimony establishing causation was required/established	Ramos presented IME reports but argued causal connection to the April 4 injury	Employer/IME physicians concluded mass unchanged and unlikely caused by industrial injury	Denied — no expert-supportable causal link shown; IMEs favored employer
Whether ALJ decision was supported by substantial evidence	Ramos contended record supported reopening	ICA/Employer contended record lacked evidence to reopen; ALJ credited medical opinions	Affirmed — court finds substantial evidence supports ALJ and ICA decision

Sun Valley Masonry, Inc. v. Indus. Comm'n, 216 Ariz. 462 (App. 2007) (deference to ALJ factfinding; burden to show new/additional/previously undiscovered condition and need for expert testimony when causation not apparent)
Phelps v. Indus. Comm'n, 155 Ariz. 501 (1987) (award will not be set aside unless unsupported by any reasonable theory of the evidence)