Zipp, Kathleen

Applicant Kathleen Zipp, a teacher, alleged a psychiatric injury arising from years of perceived harassment and disciplinary actions by her principal, vice principal, HR officer, and a department chair/coworker. The WCJ found the injury was predominantly caused (51%) by actual events of employment but barred by the good faith personnel action (GFPA) defense under Labor Code section 3208.3(h) because good faith personnel actions were a substantial cause (35%). On reconsideration, the Board found that the QME, Dr. Kothapalli, failed to identify the specific events of employment involving Theresa Ely and other 'players' and assign corresponding causation percentages, precluding a proper Rolda analysis. The Board held the QME report was not substantial medical evidence and rescinded the F&O. The matter was remanded for further development of the record, including clarification of the dates of Ms. Ely's events and supplemental opinion from the QME.