Stone, Doug

Applicant Doug Stone, a fire engineer, claimed a cumulative psychiatric injury spanning employment with Ukiah Valley Fire District (2009-2017) and the City of Ukiah (2017-2019), the latter resulting from a transfer agreement between the two entities. The WCJ found the psyche injury non-industrial and barred by Labor Code section 3208.3(b)(1) because predominant causation was not connected to the current employer (the City). The Appeals Board, after reconsideration, rescinded the F&O, holding that for a single cumulative injury the Board must look at the combined effect of all industrial exposure (including the District) and that the employment was continuous given the transfer agreement. The Board further found that because the injury arose in part from the Redwood Complex Fire—a 'direct exposure to a significant violent act'—only 35% industrial causation was required and was clearly met. The matter was returned to the trial level to determine the date of injury under section 5412, whether a single cumulative injury existed, and liability under section 5500.5(a).