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Kathryn Garnett Thompson — ADJ10372746

KATHRYN GARNETT THOMPSON, Applicant vs. COUNTY OF LOS ANGELES COMMUNITY & SENIOR SERVICES, permissibly self-insured, administered by SEDGWICK CLAIMS MANAGEMENT SERVICES, Defendants

ADJ number: ADJ10372746
Decision date: Feb 12, 2023
District office: Los Angeles
WCJ: —
Claim administrator: Sedgwick Claims Management Services
Commissioners: KATHERINE A. ZALEWSKI, CHAIR, KATHERINE WILLIAMS DODD, COMMISSIONER

Injury / body parts: psyche

LC §3208.3LC §5900LC §5903LC §5909LC §5315CCR §10507CCR §10605CCR §10845CCR §10940CCR §10392CCR §10615CCR §10840

Summary

The WCAB rescinded a WCJ's Findings and Award in a psychiatric injury case involving a County of Los Angeles employee who claimed injury to her psyche during the period May 1, 2009 through August 15, 2015. The defendant challenged the award on grounds that the WCJ failed to perform the required four-step analysis under Rolda v. Pitney Bowes regarding whether the psychiatric injury was substantially caused by lawful, nondiscriminatory, good faith personnel actions. Although the good faith personnel action defense was properly submitted for decision, neither the Opinion on Decision nor the Report included the detailed analysis mandated by Labor Code section 3208.3(h). The Board remanded the matter with instructions for the WCJ to issue a new decision containing a complete Rolda analysis, and granted the WCJ discretion to further develop the record if necessary.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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Similar decisions

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Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.