Worker's COVID Death Held Compensable Under AOE/COE Analysis

The Arizona Court of Appeals ruled that a worker’s death or injury from COVID-19 is compensable where the statutory requirements for compensability are met. Kenneth Zerby worked for Western Millwork as a design engineer. When the COVID-19 pandemic began, Western kept its employees working at the office regularly but established safety protocols based on Centers for Disease Control and Prevention guidance. Zerby had undergone a kidney transplant in 2003 and took immunosuppressants. He was also diagnosed as pre-diabetic. Zerby was nervous about contracting COVID-19, so he took pre...