McClanahan, Alonzo

Applicant Alonzo McClanahan, a construction carpenter, claimed industrial injury to his right shoulder on July 25, 2017 from lifting and carrying 20-foot 2x4s, while defendant contended it was merely a temporary exacerbation of a prior 2013 bicep injury and prior shoulder conditions. The WCJ found industrial injury based on applicant's credible testimony, treatment records, and QME Dr. McGahan's reports. Defendant petitioned for reconsideration arguing the WCJ improperly admitted QME Dr. Hanley's reports not listed on the pre-trial conference statement (violating Labor Code section 5502(d)) and erred in finding applicant credible. The majority affirmed the F&A, holding that admission of Dr. Hanley's reports was harmless error because neither the WCJ nor the Board relied on them—the decision rested on Dr. McGahan's reporting and applicant's credible testimony. Commissioner Razo dissented, arguing the admission error was not harmless and the credibility findings inadequately addressed record discrepancies, warranting remand.