Hunt, Matthew

Matthew Hunt, a CHP officer, sustained industrial injuries to numerous body parts during his 1997-2020 employment, and qualified for multiple statutory safety officer presumptions (duty belt, cancer, heart, hernia). He had a prior 2013 award of 66% permanent disability for heart and hypertension. The WCJ found that the non-attribution clause of section 4663(e) precluded apportionment under section 4663, but applied the lifetime accumulative 100% cap of section 4664(c)(1)(G), reducing the cardiovascular/catch-all region disability to an additional 34% (100% minus prior 66%), which combined with 13% for the lumbar spine yielded a net award of 43%. Applicant argued that section 4663(e) precluded application of section 4664(c). The Board denied reconsideration, holding that section 4664(c) is a lifetime accumulative cap, not an apportionment provision, and therefore is not subject to the anti-attribution clause of section 4663(e).