EZRA CENTENO vs. HARBOR FREIGHT TOOLS, SAFETY NATIONAL CASUALTY CORPORATION, CORVEL CORPORATION
This case involves an applicant claiming psychological injury, neck pain, headaches, and sleep disorder due to events at Harbor Freight Tools. The defendant argues the injury was substantially caused by lawful, non-discriminatory, good faith personnel actions, which would bar compensation under Labor Code section 3208.3(h). The Appeals Board rescinded the prior award, finding the trial judge used too narrow a standard for "good faith personnel actions" and did not adequately analyze them under the required multi-level approach. The case is returned for further proceedings to properly develop the medical record and reassess the personnel action defense.