Barrios, Alberto

Applicant Alberto Barrios, an HVAC technician, was involved in an automobile accident on July 13, 2022, and reported it but allegedly misled his employer about the details. He completed an incident report two days later listing 'none' for injured person and declined medical treatment, continued working, and was later terminated for allegedly lying about the accident. He filed a workers' comp claim after termination, which the WCJ found barred by the Labor Code section 3600(a)(10) post-termination defense, reasoning the employer lacked notice of an 'injury' because there was no disability or need for treatment before termination. The Appeals Board granted reconsideration on its own motion under Labor Code section 5900(b), rescinded the decision, and remanded for further development of the record regarding what symptoms the applicant reported prior to termination and consideration of relevant panel precedent.