Florene Hartfield vs. Los Angeles Unified School District, SEDGWICK CLAIMS MANAGEMENT SERVICES
This case involves an employee seeking increased workers' compensation for a worsening condition after a prior award. The employer argued that a portion of the increased disability should be attributed to non-industrial causes. However, the appeals board denied the employer's petition for reconsideration, finding that the medical evidence failed to properly distinguish between apportionment for the original injury and apportionment for the *increase* in disability, as required by law. Therefore, the administrative law judge's unapportioned award of new and further disability was upheld.