TRACIE KEILLOR vs. COUNTY OF SACRAMENTO
The Workers' Compensation Appeals Board (WCAB) is remanding this case for further proceedings. Initially, the WCAB reversed a judge's finding of industrial injury for a stroke under the heart presumption statute. However, the WCAB acknowledges its prior decision was incomplete as it failed to consider if the applicant could establish industrial injury outside the heart presumption, potentially requiring further medical evaluation. The WCAB also notes that a related civil case finding job stress caused the stroke is now final, raising the issue of collateral estoppel. Therefore, the case is returned to the trial level to determine if collateral estoppel applies or if further development of the record is needed to establish an industrial injury independent of the heart presumption.