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Bravo Villa, Bibiana

BIBIANA BRAVO VILLA, Applicant vs. CALAVO GROWERS, INC.; TRAVELERS PROPERTY CASUALTY COMPANY OF AMERICA, Defendants

ADJ number
ADJ12901281
Decision date
Aug 12, 2024
District office
Santa Ana
WCJ
—
Claim administrator
Travelers Property Casualty Company of America
Commissioners
—

Injury / body parts: nervous system, psyche, body systems, neck, fibromyalgia, chronic fatigue, stress

LC §3208.3

Summary

Applicant Bibiana Bravo Villa, a corporate marketing manager, claimed cumulative industrial injury to her nervous system, psyche, body systems, and in the forms of stress, fibromyalgia, chronic fatigue, and neck pain ending December 29, 2017. The WCJ found no industrial injury and issued a take-nothing order, relying on QME psychiatrist Dr. Bates and QME rheumatologist Dr. Levine. The WCAB granted reconsideration, finding the QME reports did not constitute substantial medical evidence because Dr. Levine applied an incorrect causation standard by conflating the physical injury inquiry with the heightened psychiatric causation threshold, and Dr. Bates failed to adequately explain her apportionment of causation percentages. The Board rescinded the decision and remanded for further development of the medical record to clarify the QME reports.

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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