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PanelQMEMed-legalRemanded

Brown, Audrea

AUDREA BROWN, Applicant vs. SPACE EXPLORATION TECHNOLOGIES, permissibly self-insured, administered by CORVEL, Defendants

ADJ number: ADJ10985531
Decision date: Sep 3, 2024
District office: Van Nuys
WCJ: —
Claim administrator: CorVel (administrator for Space Exploration Technologies, permissibly self-insured)
Commissioners: JOSEPH V. CAPURRO, COMMISSIONER, LISA A. SUSSMAN, DEPUTY COMMISSIONER, KATHERINE A. ZALEWSKI, CHAIR

Injury / body parts: psyche, chest, stomach, sleep disturbance

LC §3208.3LC §5313LC §5903LC §5952LC §5701LC §5906

Summary

Applicant Audrea Brown, an accounts payable specialist, alleged a cumulative industrial injury through July 20, 2017 to her psyche, chest, stomach, and in the form of sleep disturbance, attributing it largely to mistreatment by a new supervisor. The WCJ found the psychiatric injury non-industrial and ordered applicant take nothing. The psychiatric QME, Dr. Marc Charles, opined that workplace events were the predominant cause of applicant's temporary psychiatric disability but failed to perform a proper Rolda analysis breaking down causation by category of stress. The Board granted reconsideration and held the QME report did not constitute substantial evidence because it lacked the required category-by-category causation breakdown needed to assess industrial causation and the good faith personnel action defense. The Board rescinded the F&O and remanded for further proceedings and development of the medical record.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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Similar decisions

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Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.