Brown, Morgan

Applicant Morgan Brown was found by the WCJ in a January 24, 2020 Findings and Order to have sustained a psychiatric injury AOE/COE during the period August 23, 2016 through August 23, 2017, and defendant State Compensation Insurance Fund failed to establish the good faith personnel action defense under Labor Code §3208.3(h). Defendant petitioned for reconsideration, arguing the psychiatric medical reporting was not substantial medical evidence and that the WCJ failed to apply the Rolda analysis for industrial causation. After the Board granted reconsideration to study the issues, the parties participated in a commissioners' settlement conference and agreed to resolve the case by Compromise and Release. Because the District Office cannot act on a case pending reconsideration, the Board rescinded the January 24, 2020 Findings and Order and returned the matter to the WCJ to consider the C&R filed July 11, 2023. The Board emphasized this was not a ruling on the merits and that the WCJ could reinstate his decision if he declined to approve the settlement.