Fiege, Robert

Applicant Robert Fiege, a former Los Angeles County deputy sheriff, sustained a 1992 low back injury resolved by a 30.5% PD Stipulated Award, and a 1999 motor vehicle accident injury (as a bodyguard for The Officers Group) to multiple body parts that the WCJ found resulted in 100% permanent total disability. The WCJ then applied apportionment under Labor Code section 4664(b) to deduct the prior 30.5% award, reducing the award to 70%. Applicant sought reconsideration arguing the apportionment was not supported by substantial medical evidence establishing overlap between the disabilities. The Appeals Board agreed the record was deficient—no medical opinions assigned causation of work restrictions across the three injury dates, no formal rating was obtained for the 1999 injury, and the psychiatric AME's 'intertwined' causation opinion was conclusory. The Board rescinded the F&A and remanded for development of the record on permanent total disability and apportionment.