WCPanelIQ
PanelQMEGranted

Sanders, Jared

JARED SANDERS, Applicant vs. CALIFORNIA HIGHWAY PATROL, legally uninsured; administered by STATE COMPENSATION INSURANCE FUND, Defendants

ADJ number
ADJ18189096
Decision date
May 19, 2025
District office
Sacramento
WCJ
—
Claim administrator
State Compensation Insurance Fund (administering California Highway Patrol, legally uninsured)
Commissioners
JOSEPH V. CAPURRO, COMMISSIONER, KATHERINE WILLIAMS DODD, COMMISSIONER, CRAIG SNELLINGS, COMMISSIONER

Injury / body parts: lumbar spine

LC §4664LC §4663LC §5909LC §5900LC §5903LC §5952LC §5313LC §5412

Summary

Jared Sanders, a CHP officer, sustained a cumulative lumbar spine injury through March 24, 2023, with a stipulated current permanent disability of 54% before apportionment. The parties stipulated there was no basis for apportionment under section 4663 but disputed apportionment under section 4664(b) based on a prior award of 19% disability for the lumbar spine. The WCJ found 34% PPD after applying section 4664(b) apportionment. The Appeals Board granted reconsideration, finding that the prior award was not in evidence and the defendant failed to prove overlap between the prior and current disabilities as required by Kopping. The Board rescinded the F&A and returned the matter to the trial level for further proceedings.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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