Firefighter/captain John Roberts sustained a continuous trauma injury (back, right carpal tunnel) and a specific injury (cervical and lumbar spine), with all issues resolved except apportionment. The WCJ found defendant City of Los Angeles (self-insured, administered by Sedgwick) failed to meet its burden of proving non-industrial apportionment, awarding 38% PD in the CT case and 42% PD in the specific case. Defendant sought reconsideration, arguing AME Dr. Heskiaoff's apportionment opinions constituted substantial medical evidence supporting Labor Code section 4663 apportionment to the cervical and lumbar spine. The Appeals Board denied reconsideration, adopting the WCJ's Report and finding the AME's apportionment opinions were not substantial medical evidence because they merely referenced 'nonindustrial' or 'degenerative changes' without explaining how, when, or why those factors caused disability. The Board reaffirmed that defendant bears the burden of proving apportionment with substantial medical evidence framed in reasonable medical probability and supported by reasoning.
Issues
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Holding
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Analysis
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Applicant takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Defense takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Provider takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Similar decisions
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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