WCPanelIQ
PanelQMEMed-legalRemanded

Chandler, Chris

CHRIS CHANDLER, Applicant vs. ST. LOUIS RAMS, CHICAGO BEARS; TRAVELERS INDEMNITY, successor in interest by merger to GULF INSURANCE, Defendants

ADJ number
ADJ9089651
Decision date
Jan 22, 2024
District office
Santa Ana
WCJ
—
Claim administrator
Travelers Indemnity Company, successor in interest by merger to Gulf Insurance
Commissioners
ANNE SCHMITZ, DEPUTY COMMISSIONER, JOSEPH V. CAPURRO, COMMISSIONER, KATHERINE A. ZALEWSKI, CHAIR

Injury / body parts: head, neck, right shoulder, wrists, hands, ankles, sleep disorder, kidney and urinary systems, cardiovascular system, cognitive disorder, headaches

LC §4062.2LC §5904LC §4663LC §4060LC §4062LC §5412LC §4064LC §4061LC §4660LC §5900LC §4622CCR §10955

Summary

Chris Chandler, a professional football player employed by the St. Louis Rams and Chicago Bears (both insured by Travelers Indemnity) over a roughly 17-year career, claimed a cumulative trauma injury to numerous body parts. The WCJ found applicant failed to prove industrial injury, found the cumulative trauma exposure ran from January 15, 2004 through January 15, 2005, and ruled all medical and vocational reports inadmissible. The Appeals Board found multiple inconsistencies, most notably that the parties had stipulated to industrial injury and to a CT period of approximately July 1988 through December 31, 2004, which relieved applicant of his burden to prove injury. The Board held the WCJ erred in finding the reports inadmissible under section 4062.2, because under Simi and Tanksley the pre-SB 899 medical-legal procedure (former section 4062) governs claimed injuries occurring before January 1, 2005, without requiring a section 5412 date-of-injury determination. The Board rescinded the Findings and Order and returned the matter to the trial level for further proceedings and a new decision.

Issues

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Holding

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