Home/Case Law/KIRK CHRISTENSEN vs. ILLINOIS TOOL WORKS, ZURICH AMERICAN INSURANCE COMPANY, BROADSPIRE SERVICES, INC.
Regular DecisionWorkers' Compensation

KIRK CHRISTENSEN vs. ILLINOIS TOOL WORKS, ZURICH AMERICAN INSURANCE COMPANY, BROADSPIRE SERVICES, INC.

Filed: Sep 25, 2014
San Diego
ADJ7028736

CompFox AI Summary

The Appeals Board granted removal, rescinded the WCJ's decision, and ordered the defendant to authorize left knee surgery. This was based on the finding that the defendant failed to timely object to Dr. Greenfield's December 20, 2013 report and Request for Authorization, which implicitly determined the left knee injury was industrial. The Board found that the defendant's failure to object within statutory deadlines precluded them from contesting causation. Commissioner Lowe dissented, arguing Dr. Greenfield's reports did not explicitly link the left knee injury to the industrial incident.

Full Decision Text1 Pages

The Appeals Board granted removal, rescinded the WCJ's decision, and ordered the defendant to authorize left knee surgery. This was based on the finding that the defendant failed to timely object to Dr. Greenfield's December 20, 2013 report and Request for Authorization, which implicitly determined the left knee injury was industrial. The Board found that the defendant's failure to object within statutory deadlines precluded them from contesting causation. Commissioner Lowe dissented, arguing Dr. Greenfield's reports did not explicitly link the left knee injury to the industrial incident.

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