Donald Kusar vs. CITY OF LOS ANGELES
The Appeals Board granted reconsideration to address issues with the applicant's permanent disability rating after an admitted left elbow injury. The WCJ had found no permanent disability but vacated submission in companion cases involving other injuries for clarification from the Agreed Medical Examiner (AME). The applicant argued the WCJ erred by striking ratings and vacating submission in consolidated cases and that the DEU rater improperly substituted her own judgment for the AME's findings. The Board rescinded the Findings and Award, returning the matter to the trial level to rate all three consolidated cases together, and to reconsider the permanent disability rating in light of the *Blackledge* decision regarding the rater's role.