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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. ADJ10116932
Regular
Jul 15, 2019

KRIS WILSON vs. STATE OF CA CAL FIRE; legally uninsured, adjusted by STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board denied the defendant's petition for reconsideration regarding a catastrophic injury determination. The Board affirmed that the definition of "catastrophic injury" under Labor Code section 4660.1(c)(2)(B) focuses on the nature of the injury, not solely the immediate mechanism or condition after onset. The Board also rejected the argument that it exceeded its authority by outlining factors for assessing catastrophic injuries, stating these factors provide a helpful analytical framework. The defendant's petition did not dispute that the applicant sustained a catastrophic injury, raising questions about their standing as an aggrieved party.

Labor Code section 4660.1(c)(2)(B)catastrophic injuryincreased impairment ratingpsychiatric injurymechanism of injuryfact-driven inquiryen banc decisionPetition for Reconsiderationtrier of factlegislative history
References
14
Case No. ADJ8815528
Regular
Aug 22, 2016

RICARDO SALINAS vs. SOUTHEAST PERSONNEL LEASING, INC.; STATE NATIONAL INSURANCE COMPANY

The applicant sought reconsideration of a decision finding his psychiatric injury, stemming from a fall, was not compensable at an increased impairment rating. The applicant argued the injury was a "violent act" or "catastrophic" under Labor Code § 4660.1, thereby exempting it from limitations on psychiatric impairment increases. The Workers' Compensation Judge recommended denying reconsideration, finding the applicant's fall lacked the element of a violent act and that the resulting orthopedic injury and restrictions did not qualify as catastrophic. The judge concluded that the mere fact of hospitalization did not elevate the injury to catastrophic status.

Petition for ReconsiderationWorkers' Compensation Appeals Boardpsychiatric injuryLabor Code § 3208.3Labor Code § 4660.1catastrophic injuryviolent actpredominant causesix months employmentorthopedic injury
References
1
Case No. ADJ9898989
Regular
Sep 20, 2022

DOUGLAS SCHAAN vs. JERRY THOMPSON & SONS, LIBERTY MUTUAL

The applicant sought reconsideration of a Workers' Compensation Appeals Board decision that awarded 74% permanent disability, excluding psychiatric impairment. The applicant argued for 100% permanent disability and that his injury was catastrophic, entitling him to an increased rating for his psychiatric condition. The Board affirmed the original decision, finding the injury was not catastrophic under Labor Code section 4660.1(c)(2)(B) and that the applicant failed to prove he was permanently totally disabled due to the industrial injury. The applicant's vocational expert's conclusions were deemed unreliable as they improperly considered non-industrial factors and psychiatric issues outside the scope of catastrophic injury.

Permanent DisabilityCatastrophic InjuryLabor Code Section 4660.1(c)(2)(B)Qualified Medical EvaluatorWhole Person ImpairmentActivities of Daily LivingVocational RehabilitationPermanent Total DisabilityFindings and AwardReconsideration
References
7
Case No. ADJ9713798
Regular
Dec 20, 2019

BRIGETTE LEONARD vs. SANTA MONICA-MALIBU UNIFIED SCHOOL DISTRICT

The Appeals Board denied the defendant's petition for reconsideration, upholding the finding that the applicant sustained a catastrophic injury under Labor Code section 4660.1(c)(2)(B). While rejecting the WCJ's reliance on psychiatric injury to deem the physical injury catastrophic, the Board found sufficient independent evidence. Applicant's industrial thyroid cancer, requiring lifelong treatment including thyroidectomy and radioactive iodine, alongside GERD and hypertension, supports the catastrophic designation. This designation allows for an increased impairment rating for her psychiatric disability.

Labor Code section 4660.1(c)(2)(B)catastrophic injurypsychiatric injuryimpairment ratingthyroid cancerWilson v. State of CA Cal FireADLscumulative exposuretotal thyroidectomyradioactive iodine therapy
References
1
Case No. ADJ10908652, ADJ10908914
Regular
Sep 16, 2025

ZENAIDA AVILES vs. PIH HEALTH HOSPITAL, ATHENS ADMINISTRATORS

Applicant sought reconsideration of a Joint Findings and Award that denied industrial psyche injury (cumulative) and barred permanent disability from psyche injury (specific injury). Applicant contended that medical evidence supported cumulative psyche injury and that the WCJ erred in denying compensability of psychiatric permanent disability due to catastrophic consequences. The Appeals Board granted the petition for reconsideration, rescinded the prior Findings and Award, and returned the matter to the trial level for further proceedings, citing the need for further development of the medical record regarding intertwined disability and the application of the catastrophic injury exception.

Petition for ReconsiderationJoint Findings and AwardIndustrial InjuryPsycheCumulative PeriodSpecific InjuryPermanent DisabilityLabor Code section 4660.1Substantial Medical EvidenceQualified Medical Evaluator
References
27
Case No. MISSING
Regular Panel Decision
Dec 03, 2004

Claim of Scally v. Ravena Coeymans Selkirk Central School District

In this case, a claimant appealed a Workers’ Compensation Board decision regarding apportionment of her workers' compensation award. The claimant, who suffered a work-related left knee injury in 2002, had a pre-existing non-work-related injury to the same knee from 1986. While a WCLJ initially denied apportionment, the Board reversed, directing a 50/50 apportionment based on the premise that the prior injury would have resulted in a schedule loss of use award had it been work-related. The appellate court upheld the Board's determination, deferring to its interpretation that a non-work-related injury leading to a schedule loss of use constitutes a "disability in a compensation sense" for apportionment purposes. This decision was supported by medical expert testimony indicating a schedule loss of use from the prior surgery.

Workers' CompensationApportionmentKnee InjuryNon-work-related InjurySchedule Loss of UsePreexisting ConditionMedical Expert TestimonyBoard InterpretationJudicial ReviewAppellate Decision
References
13
Case No. MISSING
Regular Panel Decision

In re Eastern District Repetitive Stress Injury Litigation

The defendants sought to transfer 78 repetitive stress injury (RSI) cases from the Eastern District of New York to districts where the claims arose, also seeking severance of individual claims. Over 450 RSI cases, involving over 1,000 plaintiffs against more than 100 equipment manufacturers, were initially consolidated in the Eastern District. However, the Second Circuit later vacated the consolidation orders, finding it an abuse of discretion due to lack of common facts and varying state laws. Relying on this guidance, the court granted transfer in 75 cases and denied it in three, citing factors such as convenience of parties and witnesses, judicial economy, and the public interest in local adjudication of local controversies. The court also ordered severance where necessary to facilitate transfer.

Transfer of VenueMultidistrict LitigationRepetitive Stress InjuryProducts LiabilityForum Non ConveniensSeverance of ClaimsConsolidation of CasesJudicial EconomyWitness ConvenienceChoice of Forum
References
16
Case No. ADJ488924 (SDO 0329999), ADJ226519 (SDO 0302236), ADJ2353553 (SDO 0250184), ADJ4021935 (SDO 0269434)
Regular
Dec 10, 2020

Craig Stevens vs. Subsequent Injuries Benefits Trust Fund

The Workers' Compensation Appeals Board (WCAB) rescinded a previous order denying benefits from the Subsequent Injuries Benefits Trust Fund (SIBTF). Applicant Craig Stevens sought SIBTF benefits for a claimed subsequent cumulative trauma injury to his neck ending April 2, 2009, with a compensable consequence injury to his right shoulder and low back. The WCAB found the medical evidence regarding the causation, date of injury, and permanent disability ratings for the alleged subsequent injuries, as well as prior injuries, to be insufficient and inconsistent. The case was returned to the trial level for further development of the record, including obtaining new medical opinions to clarify the various injuries and establish SIBTF eligibility thresholds.

Subsequent Injuries Benefits Trust FundSIBTF eligibilitycumulative trauma injurycompensable consequence injurypermanent disabilityapportionmentmedical evidencecausationfurther development of the recordLabor Code section 4751
References
9
Case No. ADJ3388364 (VNO 0526713) ADJ2633182 (VNO 0342427)
Regular
Oct 24, 2014

RICHARD FROMKNECHT vs. SUBSEQUENT INJURIES BENEFITS TRUST FUND

The applicant sought reconsideration of a decision denying him benefits from the Subsequent Injuries Benefits Trust Fund (SIBTF). The applicant claimed a pre-existing disability from a 1996 spinal injury caused further permanent disability with a subsequent 1998 spinal injury. However, both injuries became permanent and stationary concurrently, meaning there was no distinct pre-existing ratable disability at the time of the second injury. Therefore, the applicant did not meet the criteria for SIBTF benefits under Labor Code section 4751, and his petition for reconsideration was denied.

Subsequent Injuries Benefits Trust FundLabor Code section 4751Petition for ReconsiderationFindings and OrderStipulations with Requests for AwardsAgreed Medical Evaluatorapportionmentpermanent and stationarypreexisting disabilityindustrial injury
References
0
Case No. ADJ5621413
Regular
Sep 15, 2016

LORI RENFRO vs. SUMMIT COUNSELING AND EDUCATION, STATE COMPENSATION INSURANCE FUND, SUBSEQUENT INJURIES BENEFIT TRUST FUND

This case involves applicant Lori Renfro's claim for Subsequent Injuries Benefit Trust Fund (SIBTF) benefits following a work injury. The WCJ initially awarded benefits, finding the industrial injury's standalone disability exceeded the 35% threshold. The SIBTF appealed, arguing the injury's standalone disability was below 35% and the prior disability should be measured at the time of the subsequent injury. The Appeals Board rescinded the award, finding the WCJ erred by not properly applying the 35% threshold for the subsequent injury alone. The matter is remanded to determine the applicability of Labor Code section 4751(a) and to re-evaluate the 70% combined disability threshold, measuring prior disability as it existed before the subsequent injury.

Subsequent Injuries Benefit Trust FundSIBTFpermanent disability thresholdapportionmentLabor Code section 4751combined disabilityprior disabilitysubsequent injuryvocational expertQME
References
4
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