Banuelos, Freddie

Applicant Freddie Banuelos, a resident manager for A-1 Mini Storage, pursued three claims: a specific right knee injury on February 1, 2015 (ADJ12979844), a cumulative orthopedic injury (ADJ12672803), and a cumulative psychiatric injury (ADJ12673709). Defendant raised the post-termination defense under Labor Code sections 3600(a)(10) and 3208.3(e), but the WCJ found the employer had notice of the injuries before termination and that applicant sought treatment beforehand. On reconsideration, the Board affirmed rejection of the post-termination defense in the specific knee and psyche claims and affirmed the right knee injury finding, but amended the cumulative orthopedic case to defer the issue of industrial injury because the WCJ found only injury of an 'orthopedic nature' without specifying a body part causing disability or medical treatment. The Board held that an unspecified 'orthopedic' finding is too uncertain to permit enforcement under Toccalino. It ordered further development of the record on the existence, nature, and extent of injuries.