Jackson, Russell

Russell Jackson, a Housing Program Assistant for the County of Riverside, alleged cumulative psychiatric and circulatory injuries (including hypertension) during October 1, 2005 through May 18, 2016. The WCJ found no AOE/COE injury and held that applicant's psychiatric claim was barred by the good faith personnel action defense under Labor Code section 3208.3(h), ordering applicant to take nothing. On reconsideration, the Board found the WCJ failed to properly perform the multi-step Rolda analysis, including failing to analyze all 18 predicate events, failing to determine actual events of employment and predominant cause, and reaching internally inconsistent conclusions about which events were good faith personnel actions. The Board also found Dr. Hyman's internal medicine QME report on hypertension was not substantial medical evidence and that the WCJ misstated the McCoy causation standard. The Board granted reconsideration, rescinded the F&O, and remanded for a new decision and development of the record.