Buck, Jeffrey

Jeffrey Buck claimed a cumulative psychiatric injury ending January 5, 2022, while employed by the State of California. The WCJ found industrial psyche injury and that defendant failed to meet its burden under the good faith personnel action defense (Labor Code § 3208.3(h)), reasoning that only the six internal investigations (30% causation total) constituted personnel actions, falling short of the predominant cause threshold. Defendant sought reconsideration. The Appeals Board granted reconsideration, finding the medical and factual record insufficiently developed because PQME Dr. Alvarez did not address stress from the day-to-day relationship with co-worker Lopez or his accusations, and it was unclear whether underlying conduct/accusations were folded into the 'investigation' causation categories. The Board rescinded the Findings of Fact and remanded for further development of the record consistent with the Rolda v. Pitney Bowes analysis.