DAVID L. BROWN vs. COUNTY OF MENDOCINO, Permissibly Self-Insured, by CLAIMS MANAGEMENT, INC.

The Workers' Compensation Appeals Board rescinded a prior award and returned the case for further proceedings, finding that the administrative law judge erred in issuing an unapportioned permanent disability award. The Board determined that the doctor's report clearly indicated overlap between the applicant's two cardiac impairments, requiring apportionment. While there was no clear evidence for apportionment to the applicant's prior spinal disability, the Board directed the trial level to obtain a new rating that accounts for the duplication in the cardiac conditions. This decision ensures a more accurate and equitable permanent disability assessment by considering the overlap in impairments.