TODD BURNS vs. COSTCO WHOLESALE, Permissibly Self-Insured, Administered By SEDGWICK CLAIMS MANAGEMENT SERVICES

This case concerns a defendant's petition for reconsideration of a Workers' Compensation Appeals Board (WCAB) decision. The WCAB denied the petition, upholding a prior award of medical treatment, including antidepressant medication, for a worker with industrial low back injuries. The defendant argued that the depression was not a compensable psychiatric injury under Labor Code section 3208.3. However, the WCAB found that the defendant's failure to conduct mandatory utilization review (UR) as required by law barred them from disputing the need for treatment. The Board affirmed that the worker is entitled to treatment, including antidepressants, for depression arising as a consequence of the established industrial low back injuries.