JOE DELIA vs. COUNTY OF LOS ANGELES/SHERIFF'S DEPARTMENT, Permissibly Self-Insured, Administered By TRISTAR RISK MANAGEMENT

This case involved a deputy sheriff who sustained multiple industrial injuries, including to his spine, hands, cardiovascular system, and auditory system. The defendant sought reconsideration of a joint award for 99% permanent disability, arguing for separate awards and apportionment. The Appeals Board denied reconsideration, affirming the WCJ's decision. The Board found that the "anti-attribution" statutes precluded apportionment for spinal, cardiovascular, and hernia injuries, and the defendant failed to prove overlap with a prior award, thus justifying a single joint award.