Applicant Gina Tetsch, an Occupational Health Nurse for Orange County Sanitation District, claimed a continuous trauma psychiatric injury (plus alleged neuro, internal, weight loss, and gastrointestinal injuries) from July 5, 2012 through June 13, 2018 based on harassment and personnel actions. The WCJ, relying on appointed regular physician Dr. David Davis, found that the actual events of employment predominantly (80%) caused the worsening of her preexisting psychiatric conditions, that good-faith personnel actions accounted for only 9.6% of causation (well below the 35-40% 'substantial cause' threshold), and awarded future medical care for the psyche injury while deferring other issues pending further development on the internal/neuro claims. Defendant filed a petition for removal challenging the finding of industrial psychiatric injury and predominant causation. The Board treated the petition as one for reconsideration because the injury/AOE-COE finding is a threshold final decision, and denied it, adopting the WCJ's report and opinion. The Board reaffirmed that aggravation of a preexisting condition is a compensable injury and that 80% work causation satisfies the predominant cause standard.
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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