RENE GARCIA vs. CITY OF ANAHEIM
The Workers' Compensation Appeals Board granted reconsideration and rescinded the prior decision regarding applicant Rene Garcia's industrial injury to his low back and knees. The Board found that the treating physician's impairment rating was not substantial evidence because it impermissibly considered the applicant's ability to compete in the open labor market, in addition to Activities of Daily Living (ADLs), deviating from *Almaraz/Guzman* guidelines. The matter was returned to the trial level for further proceedings, including a supplemental report or deposition from the physician, to clarify the *Almaraz/Guzman* analysis solely on ADLs.