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

Case No. MISSING
Regular Panel Decision

Claim Eccles v. Truck-Lite, Inc.

The claimant sustained a head injury after falling from a chair at work and sought workers' compensation benefits. The employer and its carrier disputed the claim, attributing the fall to a non-work-related medical condition. The Workers' Compensation Board ruled that the accident and injuries were not caused by the claimant's preexisting diabetic condition and awarded benefits. The employer and carrier appealed. The court affirmed the Board's decision, noting the Board's authority to assess witness credibility and medical expert opinions, and found the presumption of compensability under Workers’ Compensation Law § 21 had not been rebutted. The court also upheld the Board's rejection of the argument that the claim should be denied due to a violation of Workers’ Compensation Law § 114-a.

Workers' CompensationFall from ChairHead InjuryDiabetic ConditionHypoglycemiaPresumption of CompensabilityCredibility AssessmentMedical Expert OpinionAppellate ReviewSection 21 WCL
References
4
Case No. LBO 0370243
Regular
May 19, 2008

JOEL GRIMALDO vs. ABBEY EVENT SERVICES / STELLAR EVENT \& PRESENTATION, AMERICAN HOME INSURANCE, AIG CLAIMS SERVICES

The Workers' Compensation Appeals Board granted reconsideration and reversed a previous finding, ruling that the applicant's diabetes was not industrially caused. While the applicant sustained an admitted industrial injury to his left foot, the Board found substantial medical evidence indicating his diabetes was a pre-existing condition that complicated the foot injury rather than being caused by it. Consequently, the decision was amended to exclude diabetes as an industrial injury.

Workers' Compensation Appeals Boardindustrial injurydiabetesfoot injuryosteomyelitisamputationcausationmedical evidencereconsiderationapportionment
References
8
Case No. ADJ3588877 (SAC 0332526)
Regular
Jul 19, 2011

Laurie Shreffler vs. Electronic Data System, Hewlett Packard, Travelers Insurance Company

In this Workers' Compensation Appeals Board decision, the Appeals Board reversed the finding that the applicant sustained an industrial injury related to diabetes. The Board adopted the WCJ's report, which favored Dr. Nishimura's medical opinion over Dr. Nacouzi's regarding the diabetes. While the award for temporary and permanent disability remains, the applicant is no longer entitled to industrial medical treatment for her diabetes. The decision otherwise affirmed the original award for injuries to the neck, low back, psyche, and irritable bowel syndrome.

Workers' Compensation Appeals BoardElectronic Data SystemHewlett PackardTravelers Insurance Companyindustrial injurylow backneckpsycheirritable bowel syndromediabetes
References
1
Case No. ADJ2590975 (STK 0190237)
Regular
Sep 12, 2011

RAFAEL DELEON vs. STATE OF CALIFORNIA, CDCR, MULE CREEK PRISON, adjusted by STATE COMPENSATION INSURANCE FUND

In this workers' compensation case, the Appeals Board affirmed a prior award granting medical treatment for applicant's diabetes. Despite the defendant's argument that diabetes treatment was for a non-industrial condition, the Board found it necessary to prevent worsening of the applicant's industrially caused heart disease. Medical evaluators concluded that controlling diabetes is an essential component of treating industrial heart conditions, making the treatment compensable. The decision hinges on the principle that treatment for non-industrial conditions is covered when essential to cure or relieve the effects of an industrial injury.

Workers' Compensation Appeals BoardIndustrial InjuryHeart ConditionDiabetesGastrointestinal DifficultiesAgreed Medical EvaluatorTreating PhysicianCardiologistMedical TreatmentLabor Code Section 4600
References
9
Case No. ADJ1577836
Regular
May 04, 2009

JESUS GAVINO-REMIGIO vs. STRATUS SERVICES GROUP, STATE COMPENSATION INSURANCE FUND

This case concerns an applicant injured when stepping on a metal hook, sustaining an admitted industrial injury to his right foot. The applicant sought reconsideration after the Workers' Compensation Judge (WCJ) denied findings that the injury also affected his internal systems (diabetes), eyes, and psyche, along with associated disability. The Board denied reconsideration, finding the defendant's medical expert's opinion on non-industrial diabetes causation to be substantial evidence, while deeming the applicant's medical experts' opinions insufficient. A dissenting commissioner argued the applicant's medical evidence sufficiently supported industrial causation for diabetes aggravation, warranting reconsideration.

Workers' Compensation Appeals Boardindustrial injuryright footinternal systemseyespsychediabetes mellituspermanent disabilitytemporary disabilityGerald Markovitz M.D.
References
5
Case No. 2018-06-0105
Regular Panel Decision
Jun 25, 2018

Sims. Teresa v. Fred's, Inc.

Teresa Sims, an employee, sought the reinstatement of medical and temporary disability benefits, which her employer, Fred's Inc., had suspended. The suspension followed an authorized physician's refusal to perform surgery due to Ms. Sims' uncontrolled diabetes. Fred's argued that Ms. Sims' failure to manage her preexisting diabetes constituted non-compliance. The Court ruled in favor of Ms. Sims, determining that her need for diabetic treatment was reasonably necessary for her work-related ankle injury, as she could not afford the treatment and it became critical due to the work injury. Consequently, the Court ordered Fred's to reinstate her benefits and provide accrued temporary disability payments.

Expedited HearingBenefits ReinstatementMedical Treatment RefusalPreexisting DiabetesSurgical CancellationEmployer's Duty to TreatTemporary DisabilityMedical NecessityCausal ConnectionNon-compliance Defense
References
5
Case No. 2018-06-0105
Regular Panel Decision
Aug 31, 2018

Sims v. Fred's, Inc.

The employee, Teresa Sims, a pharmacy manager for Fred's, Inc., sustained a fractured heel bone after falling from a delivery truck. An authorized physician recommended corrective surgery, but it was deferred due to her uncontrolled diabetes, a pre-existing condition. The employer denied responsibility for treating the diabetes to facilitate the surgery, subsequently suspending the employee's benefits. The trial court ruled in favor of the employee, ordering the employer to cover the diabetes treatment, finding it causally related to the work injury. The Appeals Board affirmed this decision and remanded the case, citing the employer's failure to present specific arguments or analysis against the trial court's findings in its appellate brief.

Workers' Compensation ClaimFoot FractureDiabetes ManagementMedical CausationPre-existing ConditionEmployer LiabilityBenefits SuspensionAppellate ReviewBriefing RequirementsProcedural Deficiencies
References
3
Case No. MISSING
Regular Panel Decision

Piatt v. Welch

This opinion addresses an appeal by Leroy H. Piatt, Jr. challenging a take-nothing judgment in favor of Michael Martin Welch and The Salvation Army. Piatt contended the jury's finding that Welch's negligence did not proximately cause his injuries was factually insufficient. The case stemmed from a car accident where Welch, a diabetic, lost consciousness, ran a red light, and struck Piatt's vehicle. The core issue was whether Welch's loss of consciousness was foreseeable and if his failure to maintain his diabetes constituted negligence. The appellate court affirmed the jury's verdict, concluding that the finding was not against the great weight and preponderance of the evidence, particularly given conflicting testimony about Welch's diabetic management and the foreseeability of his blackout.

NegligenceProximate CauseFactual SufficiencyJury VerdictDiabetic ConditionLoss of ConsciousnessTraffic AccidentAppellate ReviewBurden of ProofExcuse Defense
References
12
Case No. SFO 0478857
Regular
Jan 04, 2008

GEORGE JOHNSON vs. CITY OF BRENTWOOD

The Appeals Board granted reconsideration to reverse the prior award finding industrial injury to the heart in the form of diabetes. The Board determined there was no substantial medical evidence that diabetes constituted "heart trouble" under Labor Code section 3212, as it is a risk factor, not a present cardiac condition. Consequently, the award of permanent disability and further medical treatment related to the heart was rescinded, while affirming other findings regarding a hernia.

Workers' Compensation Appeals BoardGeorge JohnsonCity of BrentwoodSFO 0478857Opinion and Order Granting ReconsiderationFindings and Awardcumulative traumapolice officerindustrial injuryhernia
References
2
Case No. MON 297119
Regular
Apr 01, 2008

EDMUND BURNS, Jr. vs. CITY OF LOS ANGELES

This case concerns a police officer who sustained an industrial injury to his right foot after stepping on a foreign object, which, due to his pre-existing diabetes, led to a gangrenous infection and amputation. The defendant argued for apportionment of the permanent disability to the applicant's diabetes, but the Appeals Board affirmed the WCJ's decision. The medical evidence indicated that the amputation would not have occurred absent the industrial injury, thus establishing industrial causation for the entire permanent disability.

Workers' Compensation Appeals BoardIndustrial InjuryPermanent DisabilityApportionmentPre-existing DiabetesCausationEscobedo v. MarshallsSenate Bill 899Qualified Medical ExaminerTreating Physician
References
8
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