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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. ADJ8128282
Regular
Jan 23, 2014

ANGELA EGBIKUADJE vs. CALIFORNIA DEPARTMENT OF CORRECTIONS AND REHABILITATIONS, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board granted reconsideration and rescinded a prior award, returning the case for further proceedings. The defendant, California Department of Corrections and Rehabilitation, argued that the applicant's psychiatric injury claim was preempted by the ADA and not proven under Labor Code section 3208.3. The Board found the original decision lacked proper analysis regarding predominant industrial causation and the good faith personnel action defense. Therefore, the case was remanded for further development of the record, including expert medical opinion on these issues.

Workers' Compensation Appeals BoardAngela EgbikuadjeCalifornia Department of Corrections and RehabilitationLegally UninsuredState Compensation Insurance FundADJ8128282Van Nuys District OfficeReconsiderationFindings and AwardIndustrial cumulative trauma injury
References
Case No. ADJ10384186 MF ADJ10404193
Regular
Mar 25, 2019

SCOTT MITCHELL vs. DENIHANA, ZURICH NORTH AMERICA

This case concerns a claim for psychiatric injury where the applicant, Scott Mitchell, alleged actual employment events were the predominant cause. The Workers' Compensation Appeals Board denied the defendant's petition for reconsideration. The Board affirmed the WCJ's findings, giving great weight to credibility determinations and finding no substantial evidence to reject them. Crucially, the Board concluded the injury was not substantially caused by lawful, nondiscriminatory, good faith personnel actions, as required by Labor Code section 3208.3. The Board relied on the agreed medical examiner's opinion that employment stress predominantly caused the aggravation of the applicant's pre-existing condition.

Labor Code 3208.3predominant causepsychiatric injurygood faith personnel actionsubstantial causecredibility determinationsaggravation of pre-existing conditionagreed medical examinercumulative traumaanxiety disorder not otherwise specified
References
Case No. ADJ9550103, ADJ9214819, ADJ9206482, ADJ9206483, ADJ9356685
Regular
Sep 04, 2014

NATHAN JACKSON vs. CITY OF LOS ANGELES

The Workers' Compensation Appeals Board denied reconsideration of an applicant's psychiatric injury claim against the City of Los Angeles. The applicant failed to demonstrate by a preponderance of the evidence that actual employment events were the predominant cause of his psychiatric injury. Even if predominant cause were established, the Board found that lawful, nondiscriminatory, good faith personnel actions by the employer substantially contributed to the injury and barred compensation. The Board's decision was based on the reasoning in the arbitrator's report, which it adopted and incorporated.

Workers' Compensation Appeals BoardPetition for ReconsiderationPsychiatric InjuryPredominant CauseActual Events of EmploymentLabor Code Section 3208.3Affirmative DefenseLawful Nondiscriminatory Good Faith Personnel ActionSubstantial CauseTreating Physician Report
References
Case No. ADJ10393124
Regular
Oct 02, 2019

MINDY SPITZ vs. REALOGY HOLDINGS CORPORATION, AMERICAN CASUALTY COMPANY OF READING, PENNSYLVANIA

The applicant, Mindy Spitz, sought workers' compensation for a psychiatric injury, claiming it resulted from a violent act at work. However, the Workers' Compensation Appeals Board (WCAB) affirmed the prior decision that she did not prove her psychiatric condition was predominantly caused by employment events. The WCAB found that the incidents described by the applicant did not constitute a "violent act" as legally defined, thus requiring the predominant cause standard for compensation. Consequently, the WCAB concluded that the applicant's claim failed under the applicable legal standard and the evidence presented.

Workers' Compensation Appeals BoardReconsiderationFindings and OrderAdministrative Law JudgeQualified Medical EvaluatorPredominant CauseSubstantial CauseViolent ActPsychiatric InjuryAOE/COE
References
Case No. ADJ9190661 ADJ9735754 ADJ9735757
Regular
Nov 20, 2015

WILLIAM CRONIN vs. HONEYWELL INTERNATIONAL INC., XL SPECIALTY INSURANCE COMPANY as administered by MATRIX ABSENCE MANAGEMENT, INC.

The Workers' Compensation Appeals Board granted reconsideration and found that William Cronin sustained a psychiatric industrial injury arising out of and in the course of employment with Honeywell International. The Board affirmed that actual employment events were predominant causes of the injury. Defendant failed to prove the injury was substantially caused by a lawful, nondiscriminatory, good faith personnel action, as the events cited did not constitute a substantial cause. The previous award was rescinded and substituted with this finding, deferring other issues.

Workers' Compensation Appeals BoardIndustrial InjuryPsychiatric InjuryActual Events of EmploymentPredominant CauseGood Faith Personnel ActionDue ProcessAdmissible EvidenceAgreed Medical ExaminerTreating Physician Reports
References
Case No. ADJ11319508
Regular
Feb 01, 2019

YVONNE GENTRY vs. DEPARTMENT OF CORRECTIONS, STATE COMPENSATION INSURANCE FUND

This case involves an applicant claiming a psychiatric injury. The Workers' Compensation Appeals Board denied the employer's petition for reconsideration, upholding the finding that actual employment events predominantly caused the applicant's psychiatric injury. The employer failed to prove that any alleged personnel actions were lawful, nondiscriminatory, and in good faith, thus failing to establish a defense against compensability. Therefore, the court found no need for a further analysis of whether such actions substantially caused the injury.

Workers' Compensation Appeals Boardpsychiatric injuryactual events of employmentpredominant causearose out of and occurred in the course of employmentAOE/COElawful nondiscriminatory good faith personnel actionaffirmative defenseburden of proofsubstantial cause
References
Case No. ADJ11952165
Regular
Nov 25, 2019

BILL HUMPHREY vs. CITY OF SAN LUIS OBISPO, PSI Through CJPIA, administered by YORK RISK GROUP

This case involved applicant Bill Humphrey's claim for psychiatric injury against the City of San Luis Obispo. The Workers' Compensation Appeals Board denied the defendant's petition for reconsideration, upholding the finding that Humphrey sustained an industrial psychiatric injury. The Board affirmed the judge's determination that while a job reclassification was a good faith personnel action, it was not the substantial cause of the injury. Instead, increased job duties and applicant's internal pressure were deemed the predominant causes of his psychiatric condition.

Labor Code Section 3208.3good faith personnel actionpsychiatric injurypredominant causesubstantial causemultilevel analysisRolda v. Pitney BowesInc.panel qualified medical evaluatorPQME
References
Case No. ADJ481349 (SAC 0357393), ADJ1911129 (SAC 0357544), ADJ7331702
Regular
Jun 18, 2015

MARIA TACLAY vs. COUNTY OF SACRAMENTO, COUNTY OF SACRAMENTO WORKERS' COMPENSATION

The Workers' Compensation Appeals Board affirmed a WCJ's finding that actual employment events on two separate dates substantially caused the applicant's psychiatric injury. The defendant, County of Sacramento, sought reconsideration, arguing that separate claims could not be combined to meet the predominant cause threshold. The Board adopted the WCJ's reasoning and upheld the original award. The decision confirms that multiple employment events, even from distinct claims, can collectively establish industrial causation for a psychiatric injury.

Workers' Compensation Appeals BoardReconsiderationFindings of FactOrder and AwardWCJPsychiatric InjuryIndustrial InjuryPredominant CauseSubstantial CauseActual Events of Employment
References
Case No. ADJ6743889
Regular
Sep 14, 2012

ALAN WAY vs. CUMMINS CAL PACIFIC, LLC, ZURICH INSURANCE GROUP

The Workers' Compensation Appeals Board denied the applicant's petition for reconsideration of a finding that he did not sustain an industrial psychiatric injury. The Board affirmed the judge's decision that the employer successfully proved the affirmative defense under Labor Code section 3208.3. This defense applies when a psychiatric injury is substantially caused by lawful, nondiscriminatory, good-faith personnel actions. The Board found that the applicant's numerous disciplinary actions, including warnings and demotions, constituted such actions and were a predominant cause of his alleged injury.

Labor Code 3208.3Psychiatric injuryIndustrial injuryPersonnel actionPredominant causeSubstantial causeGood faith personnel actionBurden of proofPetition for reconsiderationFindings and Order
References
Case No. ADJ838713 (VNO 0552616)
Regular
Apr 29, 2010

CAROL SERNA-TORRES vs. COUNTY OF LOS ANGELES

The Workers' Compensation Appeals Board granted reconsideration of an award finding the applicant suffered a cumulative psychiatric injury due to industrial stressors. Defendant argued the initial finding failed to properly analyze whether the injury was substantially caused by lawful, good faith personnel actions. The Board rescinded the award, remanding the case to determine if personnel actions were the predominant cause of the applicant's injury under *Rolda v. Pitney Bowes*. The WCJ must now specifically identify and analyze any personnel actions for lawfulness, nondiscrimination, and good faith.

Cumulative traumaPsychiatric injuryGood faith personnel actionsRolda v. Pitney BowesLabor Code section 3208.3Predominant causeCausationActual events of employmentPQMEPanel Qualified Medical Evaluator
References
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