CAROLYN LANGLEY vs. 101 CASINO, MITSUI SUMITOMO MARINE MANAGEMENT
The Workers' Compensation Appeals Board affirmed a prior award of permanent and total disability for Carolyn Langley against 101 Casino. The Board found the PQME's opinion substantial evidence supporting a combined award for two distinct industrial injuries because the physician could not reasonably apportion permanent disability between them. This conclusion aligns with case law allowing combined awards in limited circumstances where apportionment is medically speculative. The Board also found the WCJ correctly applied apportionment for a prior specific injury to the current cumulative trauma award.