In 2008, the Arizona Court of Appeals ruled that off duty officer injuries should also be covered by workers' compensation in certain circumstances. However, these claims are more complex and nuanced, and insurers often initially deny off duty workers' compensation claims. Take the case of Kelly J. Lane v. The Industrial Commission of Arizona: Kelly J. Lane, a police officer for the Tucson Police Department, was riding his mountain bike with two friends while off duty at night in rural Pinal County, Arizona. After the ride, they were standing near their vehicles when they heard gunshots. While helping his friend get behind the safety of a vehicle, Lane was shot in the back. He received emergency surgery immediately, had several more surgeries as part of his recovery, and spent 30 days in an intensive care unit. Officer lane said that he made this action to protect his friend based on his police training, and his captain concluded that he had been "acting as a law enforcement officer at the time of the shooting." However, the claim was contested by the insurance company and the administrative law judge ruled that Lane's claim was "noncompensable," saying he hadn't been acting as a peace officer at the time he was injured. Therefore, his injury didn't "aris[e] out of and in the course of his employment" as required by A.R.S. § 23-1021(A) to be covered by workers' compensation. Officer Lane appealed, making the convincing argument that his injury did, in fact, arise out of his employment because his job training as a police officer increased the risk that he would be hurt while responding to the shooting. The appeals court agreed and ruled that his injuries were indeed compensable, reversing the administrative law judge's earlier ruling. In addition, police officers and other first responders are eligible for workers' compensation in Arizona while traveling to or from work. According to Arizona law (23-1021.01): A peace officer or fire fighter as defined in section 1-215 who is injured or killed while traveling directly to or from work as a peace officer shall be considered in the course and scope of employment solely for the purposes of eligibility for workers' compensation benefits, provided that the peace officer or fire fighter is not engaged in criminal activity.