Perkins, Ronald

Ronald Perkins, a warehouse supervisor for Albertsons (self-insured, administered by Sedgwick), claimed a psychiatric injury and was hospitalized following an episode on February 5, 2019. Psychiatric QME Dr. Edward Spencer initially could not render substantial opinions because he lacked a complete medical record and an adequate examination; the Board previously (November 22, 2021) rescinded a take-nothing finding and ordered further development. After reviewing ~3,000 pages and re-examining applicant, Dr. Spencer concluded applicant's employment was the predominant cause of the psychiatric condition (55% perceived chronic discrimination, 25% acute work events, 20% cannabis use). The WCJ again found no compensable injury on January 4, 2024, and the applicant sought reconsideration. The Board granted reconsideration, rescinded the F&O, amended the application to allege a cumulative psychiatric injury, and remanded to a newly assigned WCJ to determine whether Dr. Spencer's later reports are substantial evidence and to conduct a Rolda good-faith personnel action analysis.