Raymond Mark vs. City of Los Angeles

The Workers' Compensation Appeals Board granted reconsideration of an Arbitrator's award of temporary partial disability for a sleep disorder. The defendant argued that the case fell under an ADR "carve-out" provision and that the chosen Qualified Medical Evaluator found the sleep disorder non-industrial. The Board rescinded the Arbitrator's decision because the record lacked a proper Minutes of Hearing and Summary of Evidence, which is crucial for meaningful review of ADR cases. The matter was returned to the Arbitrator for further proceedings and a new decision.