Brown, Richard

Richard Brown sought reconsideration of a WCJ's amended Findings of Fact denying him Subsequent Injuries Benefits Trust Fund (SIBTF) benefits. The WCJ found applicant did not meet the SIBTF threshold under Labor Code section 4751 because his subsequent industrial injury alone rated to 100% permanent total disability without valid apportionment, meaning the subsequent injury did not result merely in 'additional permanent partial disability' combinable with preexisting disability. The WCJ rejected the apportionment opinions of multiple evaluators (Drs. Carson, Betoushana, and Scheinbaum) as failing to constitute substantial medical evidence under Escobedo because they lacked adequate reasoning. The Appeals Board agreed, also rejecting applicant's argument that AME opinions deserved greater weight, noting the doctors were AMEs between applicant and the employer, not between applicant and SIBTF. The petition for reconsideration was denied.