CONNIE ALVIZO vs. STATE OF CALIFORNIA, DEPARTMENT OF INDUSTRIAL RELATIONS, Permissibly Uninsured, Adjusted By STATE COMPENSATION INSURANCE FUND
The Appeals Board granted reconsideration to address the defendant's challenge to a finding of permanent total disability, which was based on the now largely inapplicable "Wilkinson rule" for combining injuries. The Board rescinded the prior award and returned the case to the trial level for reevaluation in light of the recent *Benson* decision, which mandates apportionment based on causation. The defendant can raise their other contentions, such as regarding fibromyalgia and self-procured treatment, in the subsequent proceedings.