Applicant Stephen Chaplin, a transit operator for the City and County of San Francisco, sustained a specific injury on February 18, 2009 (bilateral knees, left elbow, lumbar spine) resolved by a 2013 Stipulated Award of 31% PD, and a cumulative trauma injury from December 13, 2014 to December 13, 2015 (bilateral hips, bilateral knees, lumbar spine). The WCJ found the cumulative injury caused permanent total disability (100%). Defendant sought reconsideration, arguing that Labor Code section 4664(c)(1) barred a 100% award given prior awards to the knees and lumbar spine, and that PQME Dr. Graves' reporting was not substantial medical evidence. The Board majority denied reconsideration, holding that the prior awards spanned multiple body regions, that even after subtracting prior PD the available capacity within the spine and lower extremity regions exceeded 100% when added, and that Dr. Graves properly supported addition of impairments under Vigil. Commissioner Razo dissented, arguing the prior awards must be subtracted and that Dr. Graves' opinions warranted record development.
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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