RANDOLPH ADAIR vs. SOUTHERN CALIFORNIA EDISON; Permissibly Self-Insured
This case involves applicant Randolph Adair's industrial injury claim against Southern California Edison. The Workers' Compensation Appeals Board granted reconsideration of a prior award due to disputes over the permanent disability rating. Specifically, the defendant argued the judge improperly relied on a "range of evidence" method, rather than strictly applying the AMA Guides, when evaluating medical reports on spinal translation. The Board found insufficient substantial medical evidence to support the judge's permanent disability rating and remanded the case for further medical development, potentially through an Agreed Medical Examiner. The defendant's liability for self-procured medical treatment, however, was upheld.