Sharon Levitt vs. COUNTY OF ALAMEDA, SEDGWICK 2065 OAKLAND
The Workers' Compensation Appeals Board granted reconsideration, rescinded the prior award, and returned the case for a new permanent disability rating. The Board determined that Dr. Warbritton's pre-2005 "check the box" letter did not constitute substantial medical evidence indicating the existence of permanent disability. Therefore, the 2005 Permanent Disability Rating Schedule must be applied to the applicant's injury, rendering other issues raised by the defendant moot.