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

Case No. ADJ8128282
Regular
Jan 23, 2014

ANGELA EGBIKUADJE vs. CALIFORNIA DEPARTMENT OF CORRECTIONS AND REHABILITATIONS, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board granted reconsideration and rescinded a prior award, returning the case for further proceedings. The defendant, California Department of Corrections and Rehabilitation, argued that the applicant's psychiatric injury claim was preempted by the ADA and not proven under Labor Code section 3208.3. The Board found the original decision lacked proper analysis regarding predominant industrial causation and the good faith personnel action defense. Therefore, the case was remanded for further development of the record, including expert medical opinion on these issues.

Workers' Compensation Appeals BoardAngela EgbikuadjeCalifornia Department of Corrections and RehabilitationLegally UninsuredState Compensation Insurance FundADJ8128282Van Nuys District OfficeReconsiderationFindings and AwardIndustrial cumulative trauma injury
References
Case No. ADJ9700517
Regular
Oct 05, 2018

JEANNE WILLIAMS vs. CITY OF LOS ANGELES

The Appeals Board rescinded the prior award and returned the case to the trial level for further proceedings. The Board found the original decision on the good faith personnel action defense was unclear and required further development. Specifically, the WCJ must clarify which events constituted lawful, nondiscriminatory, good faith personnel actions. The parties will then need to re-address whether these specific actions were a substantial cause of the applicant's psychiatric injury with the medical evaluator.

Workers' Compensation Appeals BoardPSYCHE INJURYGOOD FAITH PERSONNEL ACTIONLABOR CODE §3208.3(H)TEMPORARY DISABILITYPANEL QUALIFIED MEDICAL EVALUATOR (PQME)DR. ELATROZYROLDA ANALYSISSUBSTANTIAL CAUSELAWFUL PERSONNEL ACTION
References
Case No. ADJ11183246
Regular
Aug 19, 2019

RAY MASBAD vs. FOLSOM STATE PRISON, DEPARTMENT OF CORRECTIONS, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board dismissed the defendant's Petition for Reconsideration in this case. The applicant successfully proved an industrial psychiatric injury, and the defendant failed to demonstrate it was caused by lawful, good faith personnel actions. Since the applicant did not challenge the judge's findings, the Board affirmed the compensability of the injury. Consequently, the petition for reconsideration was dismissed.

Petition for ReconsiderationIndustrial InjuryPsycheLawful Personnel ActionsGood Faith Personnel ActionsDiscriminatory Personnel ActionsCompensable InjuryWCJ OpinionLegally Correct FindingsAggrieved Applicant
References
Case No. ADJ10221687
Regular
Nov 13, 2020

LEONORE MUNOZ vs. DEPARTMENT OF CORRECTIONS

Here's a summary of the case for a lawyer in four sentences: The Appeals Board reversed a Workers' Compensation Judge's decision, finding that the applicant's psychiatric injury was not substantially caused by lawful, nondiscriminatory, good faith personnel actions. While the applicant experienced distress from work-related events, including a counseling memo and an email announcing a meeting, the Board determined that the email was not a "personnel action" under Labor Code section 3208.3(h). Therefore, the employer's defense that the injury stemmed solely from such actions failed, making the psychiatric injury compensable. The Board rescinded the prior order and substituted a finding that the injury is compensable and not barred by the personnel action defense.

Workers' Compensation Appeals BoardPsychiatric InjuryGood Faith Personnel ActionLabor Code Section 3208.3(h)ReconsiderationCausationPQMEIndustrial StressorsCounseling MemoPersonnel Action
References
Case No. ADJ8984436
Regular
Aug 30, 2019

GUADALUPE RODRIGUEZ vs. COUNTY OF RIVERSIDE

This case involves applicant Guadalupe Rodriguez's claim for a psychiatric and internal system injury against County of Riverside. The administrative law judge (WCJ) denied the claim, finding it was substantially caused by lawful, good faith personnel actions under Labor Code Section 3208.3(h). The Appeals Board granted reconsideration, rescinded the WCJ's decision, and returned the case for further proceedings. This was because the WCJ and the medical evaluator's analyses regarding personnel actions and causation were deficient, requiring further development of the record.

Labor Code Section 3208.3(h)psychiatric injuryinternal system injurygood faith personnel actionsCounty of San Bernardino v. WCAB (McCoy)substantial causepredominant causeagreed medical evaluator (AME)qualified medical evaluator (PQME)Rolda analysis
References
Case No. ADJ8307593
Regular
Apr 20, 2015

BENJAMIN ILORI vs. PACIFIC PALMS CONFERENCE RESORT, ZURICH NORTH AMERICA

The Workers' Compensation Appeals Board affirmed a prior decision finding the applicant did not sustain injury arising out of and occurring in the course of employment (AOE/COE). The applicant alleged psychological injury due to perceived workplace mistreatment and discrimination, including denied promotions. The Board found that the applicant's perceived mistreatment was not substantiated by credible evidence, and any actual personnel actions were lawful, nondiscriminatory, and in good faith. Under the *Rolda* analysis, since all identified employment events were lawful personnel actions, the applicant failed to meet the burden of proof for compensable injury.

AOE/COEpsyche injurycardiovascular systemcirculatory systemmistreatmentdiscriminationpersonnel actionsRolda v. Pitney Bowlesgood faith personnel actionpredominant cause
References
Case No. ADJ12471831
Regular
Apr 14, 2025

KATHLEEN ZIPP vs. ST HELENA U.S.D., PSI, NORTH BAY SCHOOLS INSURANCE AUTHORITY

The applicant sought reconsideration of a June 13, 2023, Findings and Order (F&O) which found her psychiatric injury claim barred by the good faith personnel action (GFPA) defense under Labor Code section 3208.3(h). The Workers' Compensation Appeals Board (WCAB) rescinded the F&O, determining that the medical evidence from the Qualified Medical Evaluator (QME), Dr. Kothapalli, was not sufficiently detailed or Rolda-compliant regarding the causation percentages attributed to personnel actions by Ms. Ely and other school district 'players.' The matter was returned to the trial level for further development of the record, including clarification of events and potentially additional medical opinion, to ensure a proper substantial causation analysis.

Labor Code 3208.3Good Faith Personnel ActionPsychiatric InjuryPredominant CauseSubstantial CauseRolda AnalysisActual Events of EmploymentPersonnel ActionsLawful Nondiscriminatory Good FaithMedical Evidence
References
Case No. ADJ9320374
Regular
Jul 29, 2016

KURT KENDELL vs. COUNTY OF SAN BERNARDINO PROBATION DEPARTMENT

This case concerns a county probation officer's claim for psychiatric injury. The applicant alleged his injury stemmed from perceived bad faith personnel actions by his supervisor, including excessive report editing and workload issues. The Workers' Compensation Appeals Board (WCAB) rescinded the prior award, finding the medical evidence regarding causation and the "good faith personnel action" defense was insufficient. The matter was returned to the trial level for further proceedings to develop the record, potentially through an Agreed Medical Examiner or a court-appointed physician, to clarify the causal relationship and the nature of the employer's actions.

Psychiatric injuryGood faith personnel action defenseLabor Code section 3208.3(h)Predominant causeSubstantial evidencePanel Qualified Medical Examiner (PQME)Rolda analysisActual events of employmentLawful nondiscriminatoryMedical probability
References
Case No. ADJ6743889
Regular
Sep 14, 2012

ALAN WAY vs. CUMMINS CAL PACIFIC, LLC, ZURICH INSURANCE GROUP

The Workers' Compensation Appeals Board denied the applicant's petition for reconsideration of a finding that he did not sustain an industrial psychiatric injury. The Board affirmed the judge's decision that the employer successfully proved the affirmative defense under Labor Code section 3208.3. This defense applies when a psychiatric injury is substantially caused by lawful, nondiscriminatory, good-faith personnel actions. The Board found that the applicant's numerous disciplinary actions, including warnings and demotions, constituted such actions and were a predominant cause of his alleged injury.

Labor Code 3208.3Psychiatric injuryIndustrial injuryPersonnel actionPredominant causeSubstantial causeGood faith personnel actionBurden of proofPetition for reconsiderationFindings and Order
References
Case No. ADJ7371382
Regular
Jun 02, 2014

EARL SMITH vs. TIME WARNER CABLE; CHARTIS, administered by ACE USA

This case involves a worker claiming psychiatric injury. The defendant seeks to dismiss the claim based on the "good faith personnel action" defense under Labor Code section 3208.3(h). The Workers' Compensation Appeals Board (WCAB) granted reconsideration because the administrative law judge (WCALJ) failed to address the elements of this defense. The WCAB rescinded the previous findings and returned the case for further proceedings, requiring the WCALJ to specifically address whether the personnel actions were lawful, nondiscriminatory, and in good faith, and if they substantially caused the injury.

Workers' Compensation Appeals BoardPsychiatric injuryLabor Code section 3208.3(h)Good faith personnel actionPetition for ReconsiderationFindings of FactWCJPanel Qualified Medical ExaminerPredominant causeSubstantial cause
References
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