Hills, Lisa

Decedent Lisa Hills, a registered nurse for The Regents of the University of California, sustained needle-puncture injuries between 1979 and 1994 and tested positive for hepatitis C in 1993; she resolved two specific 1992 injuries (for 'Hepatitis') by Stipulated Award in 1995. After her death on January 29, 2017 from hepatitis C-induced hepatocellular carcinoma and cirrhosis, her daughter filed a death claim alleging a cumulative injury from January 29, 2016 to January 29, 2017. The WCJ found no cumulative injury and held the death claim time-barred under Labor Code section 5406(b) because it related back to the previously settled 1992 specific injuries. The Appeals Board granted reconsideration and rescinded the Findings, holding that the record was inadequate on the section 5402(b) presumption, that the section 5412 date of injury for a death claim depends on the beneficiary's knowledge (not the decedent's), and that the prior stipulations do not bind the applicant where unsupported by correct legal analysis. The matter was returned to the trial level for assignment to a new WCJ and further development of the record.