Priskin, Melinda

Melinda Priskin alleged a cumulative psychiatric injury (plus headaches, insomnia, and internal complaints) through February 27, 2018, while working as a team manager for Bank of America. The WCJ found defendant's claim denial untimely, triggering the section 5402(b) presumption of compensability, but ruled that the psychiatric injury was predominantly caused by lawful, nondiscriminatory, good-faith personnel actions under section 3208.3(h) and ordered applicant to take nothing. On reconsideration, the Board held that while defendant was entitled to raise the good-faith personnel action defense despite the 5402(b) presumption, the WCJ erroneously stated no psychiatric report was submitted (a QME report and treater report were in evidence) and failed to perform the required Rolda analysis. The Board rescinded the Findings and Order and returned the matter to the trial level for further proceedings, including development of the record on the alleged physical injuries.