Quiles v. Heflin Steel Supply Co‪.‬

This is a special action review of an Industrial Commission decision awarding compensation for total temporary disability. One legal issue is presented: Is a carrier entitled to a credit based upon a prior commuted award against any temporary disability compensation available to the claimant upon a subsequent reopening of his claim? We conclude that the carrier is entitled to such credit and therefore set aside the decision and award denying this credit.