LOUIE ARIAS vs. CONSOLIDATED FREIGHTWAYS CORPORATION, CIGA for RELIANCE INSURANCE
The Appeals Board rescinded the WCJ's decision and returned the cases for further proceedings. The primary issue was the WCJ's application of the Wilkinson doctrine for combining permanent disability from multiple injuries, which is no longer generally applicable post-SB 899. The Board remanded the cases to apply the new causation-based apportionment rules established in *Benson v. The Permanent Medical Group*.