WCPanelIQ
PanelQMEMed-legalGranted in Part

Galvan, Jose

JOSE GALVAN, Applicant vs. STEVE’S PROFESSIONAL WINDOW TINTING; SECURITY NATIONAL INSURANCE COMPANY, Defendants

ADJ number
ADJ11368321
Decision date
Jan 22, 2026
District office
Santa Ana
WCJ
—
Claim administrator
AmTrust Financial Services (administering for Security National Insurance Company)
Commissioners
JOSÉ H. RAZO, COMMISSIONER, CRAIG L. SNELLINGS, COMMISSIONER

Injury / body parts: head, bilateral wrists, back, ribs, brain, abdomen, bilateral upper extremities, bilateral lower extremities, lungs, kidney disease, aggravation of diabetes, PTSD/psyche

LC §5909LC §5900LC §5411LC §5412LC §4660.1LC §5701LC §4622

Summary

Jose Galvan fell about twenty feet off a ladder on May 11, 2018, while working as a window film/tint installer, sustaining numerous orthopedic and internal injuries. The WCJ found applicant 100% permanently totally disabled with injury to multiple body parts including PTSD/psyche, kidney disease, and aggravation of diabetes, and awarded temporary total disability. Defendant petitioned for reconsideration, arguing the vocational expert report was not substantial evidence, the catastrophic injury finding for psychiatric disability was unsupported, and the TD start date was erroneous. The Board granted reconsideration, finding the internal medicine PQME (Dr. Noriega) relied on an inaccurate NSAID-use history and that the psychiatric PQME (Dr. Brown) gave contradictory and unsupported opinions on psychiatric disability causation. Because the vocational report relied on these non-substantial medical opinions, it too was not substantial evidence. The Board deferred all permanent disability issues, directed further development of the record, and corrected the clerical TD date to run from May 11, 2018, to May 10, 2020.

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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