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Angela Dawson — ADJ13344359

ANGELA DAWSON, Applicant vs. PATTON STATE HOSPITAL; STATE COMPENSATION INSURANCE FUND, Defendants

ADJ number
ADJ13344359
Decision date
Mar 9, 2023
District office
Santa Barbara
WCJ
—
Claim administrator
State Compensation Insurance Fund
Commissioners
JOSÉ H. RAZO, COMMISSIONER, KATHERINE A. ZALEWSKI, CHAIR, CRAIG SNELLINGS, COMMISSIONER

Injury / body parts: psyche, internal systems

LC §5701LC §5906

Summary

Angela Dawson, a dietician at Patton State Hospital, claimed she contracted COVID-19 at work, resulting in psychiatric and internal injuries. The WCJ found no industrial injury, rejecting the PTP Dr. Brautbar's opinion as speculative and finding applicant's testimony about symptom onset not credible. The WCJ analyzed the latency period using the date of applicant's positive COVID-19 test rather than the date of symptom onset. On reconsideration, the Board found the WCJ's analysis flawed because both the PQME and PTP based their causation opinions on symptom onset rather than test date, and the WCJ improperly substituted his own analysis of latency periods for the medical experts'. The Board rescinded the February 15, 2022 Findings and Order and remanded for further development of the record with new medical opinions on when applicant developed COVID-19 and the probability of workplace exposure.

Issues

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Holding

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Analysis

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Defense takeaway

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Provider takeaway

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