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PanelDenied

Carrillo, Humberto

HUMBERTO CARRILLO, Applicant vs. CITY OF SALINAS, permissibly self-insured, administrated by CORVEL, Defendants

ADJ number: ADJ8651494
Decision date: Nov 24, 2025
District office: Salinas
WCJ: —
Claim administrator: CorVel (administrator for City of Salinas, permissibly self-insured)
Commissioners: KATHERINE A. ZALEWSKI, CHAIR, JOSEPH V. CAPURRO, COMMISSIONER, PAUL F. KELLY, COMMISSIONER

Injury / body parts: heart, hypertensive heart disease, arrhythmia, coronary atherosclerosis, eyes/retinopathy, vision, psyche, low back, right shoulder, left hand, left thumb, right hand

LC §3212LC §3212.3LC §4663LC §4664LC §5900LC §5909

Summary

Humberto Carrillo, a Salinas firefighter, sustained multiple injuries (specific and cumulative trauma) including presumptive heart, hypertension, and arrhythmia conditions under Labor Code section 3212, plus non-presumptive orthopedic, psychiatric, and vision conditions. The WCJ issued a Second Amended Findings and Award granting a single combined 100% permanent disability award across all four remaining cases. Defendant City of Salinas sought reconsideration, arguing Benson required separate awards for each injury and that the 100% award was not substantiated. The WCAB denied reconsideration, holding that the anti-attribution clause of section 4663(e) and section 3212 presumptions preclude apportionment of presumptive heart disability among injuries, supporting a single combined award per Delia v. County of Los Angeles. The Board found AME opinions substantiated adding the disabilities to reach 100%.

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.