CERI ERNE (Widow) vs. COLLINS PLUMBING, INC. and LIBERTY MUTUAL INSURANCE COMPANY
The Workers' Compensation Appeals Board granted reconsideration to further develop the medical record concerning the industrial causation of Mr. Erne's death from cardiac arrest. The Agreed Medical Examiner opined that the death was work-related primarily due to its occurrence at the workplace, but failed to analyze the specific work activities' impact on Mr. Erne's pre-existing conditions. The Board rescinded the prior finding and returned the case for further proceedings, as the initial medical evidence was deemed insufficient to establish industrial causation. One Commissioner dissented, arguing that further development was inappropriate when the applicant failed to meet their initial evidentiary burden.