CompFox AI Summary
The Appeals Board rescinded the WCJ's decision and returned the cases for further proceedings. The primary issue was the WCJ's application of the Wilkinson doctrine for combining permanent disability from multiple injuries, which is no longer generally applicable post-SB 899. The Board remanded the cases to apply the new causation-based apportionment rules established in Benson v. The Permanent Medical Group.
Full Decision Text1 Pages
The Appeals Board rescinded the WCJ's decision and returned the cases for further proceedings. The primary issue was the WCJ's application of the Wilkinson doctrine for combining permanent disability from multiple injuries, which is no longer generally applicable post-SB 899. The Board remanded the cases to apply the new causation-based apportionment rules established in Benson v. The Permanent Medical Group.
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