Extending the Traveling Employee Doctrine to Occupational Diseases: Commentary on Azorit‑Wortham v. Department of Labor & Industries (Wash. 2025)

I. Introduction

The Washington Supreme Court’s decision in Azorit‑Wortham v. Department of Labor & Industries, No. 103488‑1 (Nov. 6, 2025), marks a significant doctrinal development in state workers’ compensation law. The Court expressly holds that Washington’s “traveling employee” doctrine applies not only to sudden industrial injuries, but also to occupational diseases contracted while an employee is traveling for work.

The case arises out of the early COVID‑19 pandemic. Lisa M. Azorit‑Wortham, a flight attendant for Alaska Airlines, alleged that she contracted COVID‑19 in March 2020 as a consequence of her employment. She sought workers’ compensation benefits under Washington’s Industrial Insurance Act (IIA), Title 51 RCW, on the theory that her illness constituted an “occupational disease” because she likely contracted COVID‑19 either while performing her in‑flight duties or while traveling incident to those duties (flights, hotels, ground transportation).

Key features of the case include:

Parties:
- Petitioner: Lisa M. Azorit‑Wortham, flight attendant.
- Respondents: Washington Department of Labor & Industries (L&I) and Alaska Airlines, Inc.
Core statutory framework: The Industrial Insurance Act, particularly:
- RCW 51.32.010 (industrial injuries “in the course of employment”),
- RCW 51.32.180 (occupational diseases “in the course of employment”), and
- RCW 51.08.140 (definition of “occupational disease”).
Central legal issue: Does the traveling employee doctrine—which extends workers’ compensation coverage over the duration of a business trip—apply when the worker contracts an occupational disease (not just a sudden injury) while traveling for work?

At trial, the superior court gave two key jury instructions:

Instruction 14: A detailed and undisputed definition of “occupational disease” (tracking Dennis v. Dep’t of Labor & Industries and related precedent).
Instruction 9: A “traveling employee” instruction stating that a traveling worker is covered throughout the business trip—including travel, hotels, and meals—and that “[a]ny occupational disease occurring during such business travel is covered” by the IIA.

The jury found in favor of Ms. Azorit‑Wortham. The Court of Appeals reversed, holding that it was error to give the traveling employee instruction in an occupational disease case and that the doctrine does not apply to occupational disease claims. The Washington Supreme Court reversed the Court of Appeals, reinstating the legal validity of the jury instructions and clarifying the scope of the traveling employee doctrine.

II. Summary of the Opinion

A. Holdings

The Supreme Court’s majority (Justice Mungia) makes several key rulings:

The traveling employee doctrine applies to occupational diseases.
The Court holds that a worker who contracts a disease that otherwise meets the statutory and common‑law definition of an “occupational disease” is covered under the IIA if the disease is contracted while the worker is a “traveling employee” engaged in business travel.
Instruction 9 (traveling employee doctrine) did not alter or override the statutory definition of “occupational disease.”
The instruction correctly stated the law by identifying the temporal scope of coverage (when coverage applies) without changing the substantive definition of an occupational disease (what must be proven).
The Court of Appeals erred in concluding that the traveling employee doctrine cannot apply to occupational diseases.
The Court of Appeals’ reading of Ball‑Foster Glass Container Co. v. Giovanelli and the statutory text was too narrow and inconsistent with the mandate to construe the IIA liberally in favor of coverage.
Remand for unresolved substantial evidence issue.
Because the Court of Appeals never reached Alaska Airlines’ argument that the jury’s verdict lacked substantial evidentiary support—and because that issue was not briefed in the Supreme Court—the case is remanded for the Court of Appeals to decide that question.
No attorney fees at this stage.
Ms. Azorit‑Wortham’s request for attorney fees under RCW 51.52.130(1) is denied as premature because it remains uncertain whether she will ultimately obtain “additional relief” after remand.

B. Separate Opinion (González, J., concurring in part, dissenting in part)

Justice González agrees with the majority’s substantive legal analysis—including the extension of the traveling employee doctrine to occupational diseases and the validity of the instructions—but disagrees on the remedy. He would:

Hold that substantial evidence supports the jury verdict, and
Eliminate the need for remand, effectively reinstating the jury’s award and granting fees and costs to Azorit‑Wortham.

He reviews the evidence under the substantial evidence standard and finds it sufficient to persuade a fair‑minded, rational fact‑finder that the distinctive conditions of Azorit‑Wortham’s employment as a flight attendant—during a “Stay Home – Stay Healthy” period—more probably caused her COVID‑19 infection than conditions of everyday life.

III. Doctrinal and Factual Background

A. Factual Setting: A Flight Attendant in Early 2020

The parties stipulated that Ms. Azorit‑Wortham’s exposure window to COVID‑19 was between March 16 and March 27, 2020. During this period:

She flew on eight flights (four transcontinental).
Neither crew nor passengers were wearing masks at the time.
When not working, she largely isolated at home, limiting in‑person contact to her husband, son, and fewer than about 10 others.

In addition to in‑flight exposure, her duties required:

Travel in airports and on airplanes,
Use of hotels and airport shuttles, and
Public transportation and other settings associated with work travel.

She tested positive for COVID‑19 on April 1, shortly after the recognized exposure window.

B. Procedural History

Department and BIIA:
- L&I initially granted her workers’ compensation claim.
- Alaska Airlines appealed to the Board of Industrial Insurance Appeals (BIIA).
- An administrative law judge reversed, holding her condition was not an occupational disease; the BIIA affirmed.
Superior Court (jury trial on the BIIA record):
- Azorit‑Wortham appealed the BIIA decision to Pierce County Superior Court.
- The case proceeded to a jury trial, but only on the administrative record (transcripts) from the BIIA.
- The sole question for the jury: Did the BIIA correctly deny her occupational disease claim?
- The jury was instructed on:
  - The statutory definition of “occupational disease” (Instruction 14), and
  - The traveling employee doctrine (Instruction 9).
- The jury returned a verdict for Azorit‑Wortham.
Court of Appeals:
- Reversed, holding that:
  - The traveling employee instruction was error in an occupational disease case,
  - The error was prejudicial, requiring a new trial.
- The Court of Appeals did not reach Alaska’s alternative argument that the evidence was insufficient to support the verdict.
Supreme Court:
- Granted review.
- Held that the traveling employee doctrine does apply to occupational diseases and that Instruction 9 did not misstate the law.
- Reversed and remanded to the Court of Appeals for consideration of the unresolved substantial evidence question.

IV. Precedents and Authorities Cited

A. Dennis v. Department of Labor & Industries, 109 Wn.2d 467 (1987)

Dennis is the cornerstone of Washington’s interpretation of “arises naturally and proximately out of employment” in occupational disease cases. There, the worker had osteoarthritis that was pre‑existing and not caused by employment but was aggravated by workplace conditions. The Department argued that because the disease itself did not originate in the job, it could not be compensable as an occupational disease.

The Supreme Court rejected this narrow reading, citing the remedial nature of the IIA:

It emphasized the IIA must be liberally construed in favor of coverage, with doubts resolved for the worker.
It held that a work‑related aggravation of a non‑work‑related disease can itself qualify as an occupational disease if it arises naturally and proximately out of the employment.

Dennis set out a now‑canonical set of propositions about the “arises naturally” requirement (quoted and reaffirmed in Azorit‑Wortham):

The conditions need not be “peculiar to” or “unique to” the particular employment.
The focus is on:
“conditions giving rise to the occupational disease, or the disease-based disability resulting from work-related aggravation of a nonwork-related disease, and not upon whether the disease itself is common to that particular employment.”
The worker must show their work conditions more probably caused the disease or disability than conditions in everyday life or all employments in general.
The disease or disease-based disability must be a natural incident of the conditions of that worker’s particular employment.
The conditions causing the disease must be conditions of employment—that is, part of the worker’s particular occupation, not merely conditions that happen to exist at the workplace by coincidence.

Azorit‑Wortham leans heavily on Dennis to:

Define “arises naturally,” and
Illustrate that the IIA should not be read narrowly to exclude coverage where a fair reading would allow it.

B. Ball‑Foster Glass Container Co. v. Giovanelli, 163 Wn.2d 133 (2008)

Giovanelli is the case that first explicitly applied the traveling employee doctrine under the IIA. The employee, sent from Pennsylvania to work in Seattle, was injured by a car on his day off while walking to a park. The courts (including the Supreme Court) held:

He remained “in the course of his employment” for purposes of the IIA throughout his business trip.
Coverage extended to typical activities undertaken while away from home for work, such as “eating, sleeping, and ministering to personal needs.”

The Court of Appeals in Azorit‑Wortham relied on a footnote in Giovanelli distinguishing:

Industrial injuries: must occur “in the course of employment”; and
Occupational diseases: must both occur “in the course of employment” and “arise out of” employment.

From this, the Court of Appeals concluded that the traveling employee doctrine—designed for “course of employment” analysis for injuries—could not apply to occupational diseases, which have an additional “arising out of” requirement.

The Supreme Court rejects that inference, clarifying that:

Giovanelli supports extending “course of employment” broadly in travel contexts.
The fact that occupational diseases must also “arise out of employment” does not prevent using the traveling employee doctrine to define when the worker remains within the course of employment while away from home.

C. Clauson v. Department of Labor & Industries, 130 Wn.2d 580 (1996)

Clauson is cited for the central canon of IIA interpretation:

“The guiding principle in construing provisions of the Industrial Insurance Act is that the Act is remedial in nature and is to be liberally construed in order to achieve its purpose of providing compensation to all covered employees injured in their employment, with doubts resolved in favor of the worker.”

Azorit‑Wortham uses this canon to criticize the Court of Appeals for construing the Act in a way that limited coverage (by categorically excluding traveling employees with occupational diseases) rather than attempting to harmonize the doctrine with the statutory scheme in favor of coverage.

D. Street v. Weyerhaeuser Co., 189 Wn.2d 187 (2017)

Street is cited for an important elucidation of “arises naturally”:

“‘Arises naturally’ means that the conditions of a worker’s particular employment are distinctive, i.e., different from, employments in general or activities of daily living.”

The Court of Appeals reasoned that traveling activities (airplanes, hotels, restaurants) are “activities of daily living” and therefore not “distinctive conditions” of employment. The Supreme Court finds that analysis too rigid, particularly when read in isolation and without reference to Dennis and the liberal construction mandate.

E. Other Authorities

Medico Ins. Co., 159 Wn. App. 874 (2011) – cited by analogy for the principle that insurance policies are construed liberally to provide coverage where reasonably possible.
Anfinson v. FedEx Ground Package Sys., Inc., 174 Wn.2d 851 (2012) – provides the standard for reviewing jury instructions:
- Misstatements of law reviewed de novo.
- Reversal only if prejudicial; prejudice presumed for clear misstatements, otherwise must be shown.
Fergen v. Sestero, 182 Wn.2d 794 (2015) – underscores that a trial court’s decision to give or refuse a jury instruction is generally reviewed for abuse of discretion.
Potter v. Dep’t of L&I, 172 Wn. App. 301 (2012); Robinson v. Dep’t of L&I, 181 Wn. App. 415 (2014); Value Village v. Vasquez-Ramirez, 11 Wn. App. 2d 590 (2019) – cited in the González opinion for the substantial evidence standard and for the proposition that appellate courts do not reweigh evidence.

V. The Court’s Legal Reasoning

A. Standards of Review

The Court begins by clarifying how it reviews jury instructions:

Abuse of discretion governs the decision to give or refuse an instruction in general.
De novo review applies when the challenge asserts that an instruction misstates the law.
An instruction warrants reversal only if prejudicial:
- A clear misstatement of law is presumed prejudicial.
- A merely misleading instruction requires the challenging party to show actual prejudice.

Here, Alaska Airlines’ core argument is that Instruction 9 changed the law by granting automatic coverage for any disease contracted during business travel, effectively rewriting the statutory definition of “occupational disease.” That is a legal‑accuracy argument, so the Court applies de novo review.

B. Distinguishing “When Coverage Applies” from “What Qualifies as an Occupational Disease”

The majority’s key analytical move is to separate two questions:

Temporal/positional coverage: “When is the employee considered to be in the course of employment?”
Substantive qualification: “Does the condition satisfy the statutory definition of an ‘occupational disease’?”

Instruction 9 deals only with question (1). It states that a traveling employee is “subject to workers’ compensation coverage throughout the duration of the business trip,” including travel, hotel stays, and restaurant meals, and that “[a]ny occupational disease occurring during such business travel is covered.” The majority interprets this as:

A rule about the time period and context in which the worker is in the “course of employment.”
Not a redefinition of what counts as an “occupational disease.”

Instruction 14, by contrast, sets out the full statutory definitionDennis.

Thus:

“In short, instruction 9 simply provides the temporal term for IIA coverage—i.e., during the time the employee is traveling for work they will be covered—while instruction 14 sets forth the definitional terms that need to be met to obtain coverage.”

Alaska’s own closing argument, quoted in the opinion, undercuts its legal claim: counsel explicitly told the jury that Instruction 9 “does not trump Instruction No. 14,” and that the jury still had to find the condition arose “naturally and proximately from the distinctive conditions of employment.” This indicates that, functionally, the instructions operated as the trial court and majority understood them: complementary, not conflicting.

C. Liberal Construction of the IIA and Critique of the Court of Appeals

The Court emphasizes the longstanding rule that the IIA is remedial and must be liberally construed in favor of the worker, citing Clauson. It notes that this approach parallels the general rule for construing insurance contracts—to favor coverage where reasonably possible.

The majority faults the Court of Appeals for:

Failing even to mention this liberal construction principle in its analysis.
Recasting the statutory and doctrinal language to restrict rather than facilitate coverage.

Specifically, the Court of Appeals:

Relied on Giovanelli’s footnote distinction between injuries and occupational diseases to exclude occupational disease claims from the traveling employee doctrine.
Characterized eating, sleeping, and personal‑needs activities during travel as mere “conditions of everyday life” and therefore incapable of supporting an occupational disease claim.

The Supreme Court responds by:

Reaffirming that “arises naturally” must be interpreted liberally, not as a narrow gatekeeping device.
Pointing back to Dennis, which held:
- Coverage must not be refused merely because the underlying disease did not originate in the workplace.
- The Act’s purpose is to provide “sure and certain relief” to all covered workers, whether their harm stems from a sudden injury or from a disease (including aggravated conditions).
Emphasizing that both injuries and occupational diseases can arise out of work conditions, and the Act expressly aims to treat them comparably.

D. Reaffirmation of the Dennis Framework in a Modern Context

The majority reproduces the five Dennis propositions in full, then explains that Instruction 14 forced the jury to apply that test. Thus, to find in Azorit‑Wortham’s favor, the jury necessarily concluded that:

The conditions of her work (which included flight duties and travel) more probably caused her COVID‑19 infection than conditions of everyday life or employments in general.
The risk of COVID‑19 infection, in the way and circumstances she experienced it, was a natural incident of her particular employment as a flight attendant performing essential, high‑exposure work in March 2020.
The causative conditions were indeed conditions of her employment, not merely coincidental conditions at her workplace or in the broader population.

The majority does not reassess the evidentiary record; it preserves that task for the Court of Appeals on remand. But legally, it makes clear that nothing in the traveling employee doctrine undermines or replaces the Dennis test. Instead, the doctrine tells us that:

Flying, staying at hotels, and eating out while on assignment are within the course of employment for a traveling employee.
If these work‑related activities expose the worker to distinctive risks sufficient to satisfy Dennis, the resulting disease can be an occupational disease—even if comparable activities might occur in everyday life for other people.

E. Remand on Substantial Evidence and the Scope of Review

Because the Court of Appeals never reached Alaska Airlines’ substantial evidence challenge, and neither party briefed that issue in the Supreme Court, the majority declines to resolve it. Instead, it reverses the erroneous legal holding about the traveling employee doctrine and remands for the Court of Appeals to decide whether the record contains substantial evidence to support the jury’s verdict under the correct legal standard.

This division of labor reflects:

Respect for the appellate hierarchy and issue‑preservation principles.
An understanding that substantial evidence review is fact‑intensive and was not fully aired before the Supreme Court.

F. Justice González’s Concurrence/Dissent: No Need for Remand

Justice González agrees entirely with the majority on the key legal propositions but parts ways on what to do next.

He applies the substantial evidence standard, citing Potter, Robinson, and Value Village:

Substantial evidence is evidence “sufficient to persuade a fair‑minded, rational person of the truth of the matter.”
Evidence must be viewed in the light most favorable to the party that prevailed in superior court (here, Azorit‑Wortham).
The appellate court must not reweigh evidence or assess witness credibility.

González emphasizes several evidentiary points:

Alaska Airlines did not dispute that COVID‑19 is contagious or that Azorit‑Wortham had it.
During the likely exposure period, she:
- Took eight flights,
- Worked in confined spaces within six feet of unmasked people,
- Used hotels, ground transport, and airport shuttles as part of her job.
Her job was performed during a “Stay Home – Stay Healthy” emergency order, when the general population was directed to minimize contact, but she, as an essential worker, had to continue high‑exposure duties.
A medical expert testified that:
- She likely contracted the virus in a work setting, and
- Her work conditions were a “perfect storm” for contracting COVID‑19.

On this record, he concludes that a rational juror could find that the distinctive conditions of her employment more probably caused her infection than non‑work exposures, satisfying Dennis. Thus, he would:

Affirm the jury verdict outright instead of remanding.
Grant attorney fees and costs under RCW 51.52.130, reasoning that her successful Supreme Court appeal effectively reinstated the verdict.

Although not controlling, his analysis offers a clear template of how Washington appellate courts might assess evidence in future infectious disease cases involving traveling or front‑line workers.

VI. Impact and Future Implications

A. Clarified Rule: Traveling Employee Doctrine Extends to Occupational Diseases

The case establishes a new, explicit rule in Washington:

The traveling employee doctrine applies to occupational disease claims under the Industrial Insurance Act. A traveling employee remains in the course of employment throughout the business trip, and any disease that qualifies as an occupational disease under RCW 51.08.140 and the Dennis factors is potentially compensable even if contracted during ordinary activities (e.g., flying, sleeping, eating) undertaken while traveling for work.

Future litigants now have clear precedent that:

They may combine the traveling employee doctrine (for “course of employment”) with the occupational disease framework (for “arises naturally and proximately out of employment”).
Employers and insurers cannot defeat claims simply by arguing that travel‑related activities resemble “everyday life” if the exposure risk was materially heightened by the job’s distinctive demands.

B. Pandemic and Infectious Disease Claims

Although the legal principle is not limited to COVID‑19, the decision inevitably has special relevance to infectious disease claims:

High‑exposure occupations: Flight attendants, health‑care workers, first responders, and others whose work requires them to:
- Traverse multiple locations,
- Interact closely with numerous individuals, and
- Remain mobile when much of the population is sheltering.
Proof challenges: Claimants will still need to show:
- Work more probably caused the infection than everyday life (or all employments in general), and
- The exposure was a natural incident of their particular employment, distinctive relative to the general population.

Azorit‑Wortham does not create automatic coverage for all infectious diseases contracted while traveling. It preserves the causation and distinctiveness requirements of Dennis. But it removes a doctrinal barrier that could have categorically excluded traveling workers from occupational disease coverage for travel‑based exposures.

C. Guidance on Jury Instructions

The decision also gives valuable guidance on drafting instructions in IIA cases:

Courts may safely instruct juries on the traveling employee doctrine in occupational disease cases, provided:
- The occupational disease definition (Instruction 14‑type language) is also given, and
- The instructions make clear that both the course‑of‑employment and arises naturally/proximately requirements must be met.
Counsel can argue, as Alaska did, that:
- Being in the course of employment (via Instruction 9) is necessary but not sufficient, and
- The worker must also satisfy the occupational disease criteria.

This should diminish future disputes over whether traveling employee instructions “conflict” with occupational disease instructions. The Court has stated unequivocally that the doctrines are complementary.

D. Reaffirmation of Liberal Construction

The decision re‑centers the liberal construction principle in IIA interpretation. This signals that:

Appellate courts should be cautious about reading implied limitations into the Act that restrict coverage.
When statutory language and precedent reasonably permit coverage, the Act should be read to allow, rather than deny, benefits.

For practitioners, this reinforces the utility of:

Framing arguments around the IIA’s remedial purpose, and
Highlighting how excluding coverage would undermine that purpose in modern workplace conditions (including pandemics and remote or travel‑heavy work).

E. Remaining Uncertainties

The Court’s remand leaves one important issue unresolved for this particular case:
- Whether substantial evidence supports the jury’s finding that this COVID‑19 case satisfied the occupational disease standard.
Thus, while the doctrinal framework is settled, the evidentiary thresholds for infectious disease cases will continue to be developed in:
- The Court of Appeals’ decision on remand, and
- Future cases that apply Dennis to modern disease‑transmission scenarios.
Justice González’s opinion previews one path: considering the combination of essential‑worker status, high‑density and confined‑space exposure, timing relative to public health orders, and expert testimony as sufficient to meet the substantial evidence standard.

VII. Complex Concepts Explained in Plain Terms

A. “Occupational Disease”

Under RCW 51.08.140, an “occupational disease” is:

A disease or infection that arises naturally and proximately out of the worker’s employment.

In simpler terms:
- The disease does not have to be unique to the job, and it does not have to originate there.
- But the job conditions must make it more likely that the worker got (or worsened) the disease than everyday life would have.
- The disease must be a normal or expected risk of that kind of job, not just something that happened to occur while the worker happened to be at work.
B. “Arises Naturally”

“Arises naturally” does not mean:
- “Caused only by work,” or
- “Unique to this job.”
Instead, as Dennis and Street explain, it means:
- The job’s conditions are distinctive compared to:
  - General life outside of work, and
  - Employment in general.
- Those distinctive conditions make the disease a natural incident of doing that job.
- The job likely contributed more to causing or worsening the disease than ordinary living conditions did.
C. “Proximate Cause”

“Proximate cause” is essentially legal causation: the job conditions must be a:
- Direct and significant cause of the disease, and
- Condition “without which such condition would not have happened,” in the language of the jury instructions.
This does not mean the job must be the only cause, but it must be a crucial contributing factor in a direct chain of events leading to the disease or its worsening.

D. “Conditions of Everyday Life”

The statute and instructions say that a disease does not arise naturally out of employment if it is caused by:
- “Conditions of everyday life,” or
- “Conditions of all employments in general.”
This is a way to exclude diseases that:
- Most people are equally exposed to, whether they work or not, and
- Are not linked to particular job‑related exposures or risks.
Yet, as Azorit‑Wortham makes clear, activities that might look like “everyday life” (eating in a restaurant, sleeping in a hotel) can still be distinctive when:
- The worker must do them much more frequently or intensively because of the job, and
- They occur under conditions that materially increase risk (e.g., repeated confined‑space presence with large numbers of unmasked people during a pandemic).
E. Traveling Employee Doctrine

The traveling employee doctrine answers this question:

“When a worker is traveling away from home for work, when are they considered to be ‘in the course of employment’ for workers’ compensation purposes?”

The doctrine generally holds:
- A worker sent away from home for business is in the course of employment for the entire trip, not just during on‑the‑clock task performance.
- Coverage extends to:
  - Travel between locations,
  - Hotel stays,
  - Meals, and
  - Reasonable personal‑comfort activities (e.g., walking to nearby amenities).
Azorit‑Wortham extends this doctrine to occupational disease cases, clarifying that:
- A disease contracted during business travel can be compensable if it otherwise meets the “occupational disease” definition.
- Simply being on a trip does not guarantee coverage—causation, distinctiveness, and proximate cause must still be proven.
F. “Liberal Construction” of the IIA

“Liberal construction” means:
- When reasonable interpretations exist, courts should choose the one that favors coverage for injured workers, consistent with the IIA’s remedial purpose.
- Courts should avoid technical or narrow readings that would arbitrarily deprive workers of benefits when the statute can fairly be read to cover them.
This does not mean every claim must be granted. It means doubtful questions about the meaning of the law (as opposed to facts) should generally be resolved in favor of coverage.

VIII. Conclusion

Azorit‑Wortham v. Department of Labor & Industries establishes a clear and important precedent in Washington workers’ compensation law: the traveling employee doctrine applies fully to occupational disease claims under the Industrial Insurance Act. The doctrine defines the temporal scope of employment for workers on business trips, ensuring that they are deemed “in the course of employment” throughout the trip—not only at their nominal worksites.

At the same time, the Court reaffirms and applies the Dennis framework for what it means for a disease to “arise naturally and proximately out of employment.” A disease contracted while traveling is not automatically compensable; the claimant must still prove:
- Distinctive employment conditions,
- Greater exposure than everyday life or general employment,
- Proximate causation, and
- That the harmful conditions are truly conditions of employment.
By correcting the Court of Appeals and rejecting a categorical bar on traveling‑employee occupational disease claims, the Court:
- Aligns doctrine with the IIA’s remedial purpose and liberal construction mandate.
- Provides crucial guidance for handling pandemic‑related and other infectious disease claims involving traveling and high‑exposure workers.
- Clarifies that injury and disease are to be treated on an equal footing under the Act, as the legislature intended.
Although the ultimate outcome for Ms. Azorit‑Wortham hinges on the Court of Appeals’ substantial evidence analysis on remand, the legal significance of this opinion is already clear. It modernizes and harmonizes Washington’s workers’ compensation doctrine with the realities of mobile, travel‑intensive work and emergent public health risks, while robustly reaffirming core principles developed in Dennis, Giovanelli, and Clauson.