ROBERT JELENIC vs. LOS ANGELES DEPARTMENT OF WATER AND POWER
This case involves a dispute over permanent and total disability following a 1997 industrial injury. The Appeals Board affirmed the finding of permanent and total disability, including the applicant's upper and lower back in the industrial injury. However, the Board rescinded the original finding that apportionment to non-industrial factors was inapplicable, stating apportionment under Labor Code section 4663 should be considered. The majority found Dr. Richman's apportionment opinions did not provide substantial evidence for apportionment, while the dissenting opinion argued for further development of the record regarding apportionment to a 1992 non-industrial injury.