Martin, Ellen

Applicant Ellen Martin, a park ranger, sustained an admitted industrial injury to her head, vision, and psyche (with disputed brain and neuro-psyche claims) on June 3, 2020. The WCJ found permanent and total disability, primarily by adding rather than combining the neurology QME's impairment ratings for post-traumatic headaches (50% PD) and vertigo/disequilibrium (60% PD). Defendant sought reconsideration, arguing the QME's reporting was not substantial medical evidence (resting on subjective complaints) and that the CVC was not properly rebutted to justify addition over combination. The majority (Dodd, Capurro) denied reconsideration, holding the QME's reporting constituted substantial evidence and adequately demonstrated no overlap in ADLs under Vigil, while noting that even combining the neurology ratings plus the AME's neuropsychological disability would still yield total disability. Commissioner Razo dissented, arguing the impairment rested on subjective complaints lacking objective clinical correlation and the no-overlap analysis was conclusory.