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Case Law Database

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

Case No. MON 0300616(MF) MON 0337809
Regular
Jun 04, 2008

NANCY VALENTINE vs. TRADER JOE'S, SAINT PAUL'S FIRE AND MARINE

The Appeals Board granted reconsideration of a workers' compensation judge's decision finding industrial injuries to the applicant's shoulder and neck, as well as a psychiatric injury meeting the predominant threshold for benefits. The employer sought reconsideration, arguing the judge erred in evaluating evidence, analyzing the psychiatric injury, and denying due process through time restrictions and lack of service. The Board granted reconsideration to review the proceeding transcript to fully understand the disputed issues and ensure a just decision.

Workers' Compensation Appeals BoardReconsiderationAdministrative Law JudgeIndustrial InjuryLeft ShoulderNeckPsychiatric InjuryPredominant ThresholdLabor Code section 3208.3(b)(1)Temporary Disability Indemnity
References
1
Case No. ADJ481349 (SAC 0357393), ADJ1911129 (SAC 0357544), ADJ7331702
Regular
Jun 18, 2015

MARIA TACLAY vs. COUNTY OF SACRAMENTO, COUNTY OF SACRAMENTO WORKERS' COMPENSATION

The Workers' Compensation Appeals Board affirmed a WCJ's finding that actual employment events on two separate dates substantially caused the applicant's psychiatric injury. The defendant, County of Sacramento, sought reconsideration, arguing that separate claims could not be combined to meet the predominant cause threshold. The Board adopted the WCJ's reasoning and upheld the original award. The decision confirms that multiple employment events, even from distinct claims, can collectively establish industrial causation for a psychiatric injury.

Workers' Compensation Appeals BoardReconsiderationFindings of FactOrder and AwardWCJPsychiatric InjuryIndustrial InjuryPredominant CauseSubstantial CauseActual Events of Employment
References
0
Case No. ADJ3135090 (SAC 0355157) ADJ6834808
Regular
Sep 12, 2019

GUY LEE vs. UOP/MCGEORGE SCHOOL OF LAW, SUBSEQUENT INJURIES BENEFITS TRUST FUND

The Workers' Compensation Appeals Board affirmed the WCJ's decision denying benefits from the Subsequent Injuries Benefits Trust Fund (SIBTF). Applicant's prior stipulation dismissing claims for sleep disturbance, sexual dysfunction, and psychiatric injury bound him from pursuing these for SIBTF benefits. Even without those dismissals, applicant's permanent disability rating for the subsequent injury, after adjustments, did not meet the 35% threshold required for SIBTF eligibility. The WCJ's finding that the industrial injury was not the predominant cause of the claimed psychiatric injury also contributed to the denial.

Subsequent Injuries Benefits Trust FundLabor Code section 4751permanent partial disabilitystipulated dismissalpredominant causepsychiatric injurybilateral carpal tunneldiminished future earning capacityWCJWorkers' Compensation Appeals Board
References
4
Case No. ADJ6967163
Regular
Nov 05, 2015

CAROLYN WILLIAMSON vs. HARRIS DIRECT, INC., STATE FARM INSURANCE COMPANY

This case involves an applicant seeking reconsideration of a denial for workers' compensation benefits due to a cumulative trauma injury. The administrative law judge found her psyche injury barred because it was predominantly caused by the employer's lawful, good faith personnel actions, including termination. The applicant argued harassment and unjust treatment exceeded this threshold, but her petition was denied. The Board affirmed the denial, finding no substantial medical evidence to support the applicant's claim of industrial causation for her psyche, back, and internal injuries, as these were primarily linked to the employer's actions or pre-existing conditions.

Good faith personnel actionsPsychiatric injuryCumulative traumaLabor Code 3208.3(h)ApportionmentMedical evidenceWCJ findingsSubstantial medical evidencePredominant causeIndustrial causation
References
11
Case No. ADJ8777230
Regular
Jun 29, 2015

TIMETHY BLAKELEY vs. AIR RESOURCES BOARD, STATE COMPENSATION INSURANCE FUND

This case concerns a petition for reconsideration filed by the defendants, Air Resources Board and State Compensation Insurance Fund, following a Workers' Compensation Appeals Board (WCAB) decision that awarded benefits to Timothy Blakeley. The defendants argued the administrative law judge erred in determining Blakeley's psychiatric injury was not primarily caused by lawful personnel actions and that the causation threshold was misapplied. The WCAB denied the petition, adopting the WCJ's report which found the defendants failed to demonstrate the personnel actions were in good faith and that the applicant's injury was predominantly work-related. The WCAB gave significant weight to the WCJ's credibility determination of the applicant's testimony.

Workers' Compensation Appeals BoardPetition for ReconsiderationWCJ credibility determinationLabor Code §3208.3(h)substantial causegood faith personnel actionpsychiatric injuryAir Resources BoardSCIFAME Dr. Donald Feldman
References
2
Case No. ADJ10715455
Regular
Mar 18, 2019

MICHAEL KAMM vs. COUNTY OF MONTEREY, P.S.I., administered by INTERCARE HOLDINGS INSURANCE SERVICES, INC.

In this case, the Appeals Board partially rescinded the WCJ's award for psychiatric injury due to inconsistencies in the medical opinion regarding predominant causation. While the Board affirmed the rejection of the good faith personnel action defense, it found Dr. Lopez's opinion lacked clarity on whether employment events were the predominant cause of the applicant's overall psychiatric disability. Therefore, the matter is returned to the WCJ for further development of the medical record to clarify predominant causation before a new decision can be issued.

Workers' Compensation Appeals BoardReconsiderationPsychiatric InjuryPredominant CausationLabor Code Section 3208.3(h)Good Faith Personnel Action DefensePanel Qualified Medical Evaluator (PQME)Dr. LopezAnxiety DisorderMajor Depression
References
3
Case No. ADJ10301846 ADJ8235335
Regular
Feb 07, 2019

Jack Kessler vs. E. \u0026 J. Gallo Winery

Defendant E. & J. Gallo Winery sought reconsideration of a Workers' Compensation Appeals Board decision that found applicant Jack Kessler sustained a compensable psychiatric injury. The Board denied reconsideration, affirming the administrative law judge's finding that industrial factors were the predominant cause of the applicant's psyche injury. The defendant argued the applicant failed to meet the "predominant cause" standard for psychiatric injuries and that combining two separate injuries was impermissible. The Board clarified that the issue of injury causation is distinct from the apportionment of permanent disability, and the applicant's medical evidence met the predominant cause standard.

Workers' Compensation Appeals BoardPetition for ReconsiderationNew and Further DisabilityPsyche InjuryPredominant CauseLabor Code section 3208.2Labor Code section 3208.3Cumulative TraumaSpecific InjuryApportionment
References
5
Case No. ADJ5621413
Regular
Sep 15, 2016

LORI RENFRO vs. SUMMIT COUNSELING AND EDUCATION, STATE COMPENSATION INSURANCE FUND, SUBSEQUENT INJURIES BENEFIT TRUST FUND

This case involves applicant Lori Renfro's claim for Subsequent Injuries Benefit Trust Fund (SIBTF) benefits following a work injury. The WCJ initially awarded benefits, finding the industrial injury's standalone disability exceeded the 35% threshold. The SIBTF appealed, arguing the injury's standalone disability was below 35% and the prior disability should be measured at the time of the subsequent injury. The Appeals Board rescinded the award, finding the WCJ erred by not properly applying the 35% threshold for the subsequent injury alone. The matter is remanded to determine the applicability of Labor Code section 4751(a) and to re-evaluate the 70% combined disability threshold, measuring prior disability as it existed before the subsequent injury.

Subsequent Injuries Benefit Trust FundSIBTFpermanent disability thresholdapportionmentLabor Code section 4751combined disabilityprior disabilitysubsequent injuryvocational expertQME
References
4
Case No. MISSING
Regular Panel Decision

Matter of Kent v. Cuomo

Petitioners, state employees typically ineligible for overtime, challenged a determination by the State Budget Director regarding overtime compensation following Hurricane Sandy. The Budget Director's bulletin authorized overtime for hours worked beyond 47.5 per week, rather than the 40-hour threshold sought by petitioners. Petitioners argued that the Budget Director was statutorily required to compensate for all hours over 40. The Supreme Court partially dismissed their application, leading to this appeal. The appellate court deferred to the Budget Director's interpretation of Civil Service Law § 134 (6), finding the 47.5-hour threshold was not irrational or unreasonable given the agency's expertise and consistent past application. The court also held that employer respondents did not act irrationally in not requesting compensation below the 47.5-hour threshold, as this authority rests solely with the Budget Director.

Overtime CompensationExtreme EmergencyHurricane SandyState EmployeesCivil Service LawStatutory InterpretationAdministrative DiscretionNormal Workweek47.5-Hour ThresholdCPLR Article 78
References
8
Case No. ADJ5774907
Regular
Jan 15, 2014

ROBERT PORTER vs. LOWE'S HOME IMPROVEMENT WAREHOUSE, INC.; SEDGWICK CLAIMS MANAGEMENT SERVICES, INC.

The Appeals Board granted the defendant's Petition for Removal, overturning a prior order that dismissed the case from the trial calendar. The defendant seeks to litigate the statute of limitations as a threshold issue, arguing it was improperly denied. The Board found that statute of limitations is a threshold issue that can be bifurcated and that the prior denial of a dismissal petition was procedural, not on the merits. The case is returned to the trial level for proceedings on the statute of limitations.

Petition for RemovalStatute of LimitationsJurisdictionRes JudicataThreshold IssueLabor Code Section 5405Affirmative DefenseBifurcationDeclaration of ReadinessOff Calendar
References
3
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