Clinton, Andre

Applicant Andre Clinton, a principal analyst for the County of Los Angeles, claimed a psychiatric injury (Major Depressive Disorder) AOE/COE attributed primarily to the conduct of his supervisor John Ortega. The WCJ found no compensable psychiatric injury and ordered applicant take nothing, finding the claim barred by the good faith personnel action defense under Labor Code section 3208.3(h). The WCAB granted reconsideration, finding the WCJ's analysis incomplete and internally inconsistent, noting that the F&O found no AOE/COE injury while the Opinion on Decision stated applicant did sustain a psychiatric industrial injury. The Board found that AME Dr. Sones failed to separately discuss and analyze numerous causal factors and events, and that the WCJ failed to specify which events were actual events of employment and which were the predominant cause. The Board rescinded the F&O and remanded for further development of the record and a complete Rolda analysis.