GLEN HODGES vs. STATE OF CALIFORNIA
This case concerns a firefighter's claim for melanoma under Labor Code section 3212.1, which presumes cancer is industrially caused. While the applicant raised the presumption through evidence of carcinogen exposure, the Appeals Board overturned the initial finding of industrial injury due to melanoma. The Board found the presumption was rebutted by expert medical opinion concluding the applicant's melanoma was not reasonably linked to industrial sun exposure, citing significant childhood sun exposure, tanning bed use, family history, and minimal workplace sun exposure to the affected area. The Board therefore granted reconsideration and amended the decision to exclude melanoma as an industrial injury, though actinic keratosis was still found to be industrially caused.