Cited by

Comm’n, -12 (1978) (affirming denial of highway patrol officer’s claim for mental injury benefits arising from “the usual[,] ordinary and expected incidents of his job”); Muse v. Indus.

Comm’n, -12 (1978) (affirming the non-compensability of a claim for mental injury where the claimant “was exposed to nothing other than the usual ordinary and expected incidents of his job as a Highway Patrolman”).

See Sloss v. Industrial Comm’n, , (claimant whose nervous condition caused him to suffer from gastritis did not have compensable claim because he was not exposed to any additional stress other than the usual, ordinary, and expected stress inherent in his employment); cf. Pima Community College v. Industrial Comm’n

The court of appeals relied on three cases to support its holding that there was no injury by accident: Lapare v. Industrial Comm’n, , Pima Community College v. Industrial Comm’n, , and Sloss v. Industrial Comm’n

In Sloss v. Industrial Comm’n, , our supreme court held that a physical injury caused by job-related emotional stress is not compensable unless the stress *496 is unusual, unexpected, or extraordinary.

Prior to Archer , in Sloss v. Industrial Comm’n., , the Supreme Court of Arizona affirmed an award which held that: [T]he stresses to which the applicant was exposed in his employment were the same as, and no greater than those imposed upon all other Highway Patrolmen.

(more than insubstantial or slight) (requiring a recognizable causal connection showing that the exertions or work of the job precipitated the heart attack) (exposure to nothing other than the usual, ordinary and expected incidents of a job as highway patrolman is not compensable).

Further, in Sloss v. Industrial Comm’n, , our supreme court set the following limitations on its holding in Fireman’s Fund: Fireman’s Fund does not mean that every emotional condition even though work-related is compensable____ To qualify as an injury by accident, the condition must have been produced by the unexpected, the unusual, or

Our decisions in Fireman’s Fund & , , both involving job-related stress, required that an emotional condition must have been produced by some unexpected, unusual or extraordinary stress to qualify as an injury by accident.

In other words, the stress must be “unexpected, unusual or extraordinary.” 2

which held that gastritis and chronic anxiety resulting from the everyday pressures of performing the duties of a highway patrolman were not compensable in the absence of a showing that the work performed exposed the claimant to the “unexpected, the unusual or the extraordinary stress” not experi

P.2d 303, 304 (1978), the court stated: Fireman’s Fund does not mean that every emotional condition even though work-related is compensable.