WCPanelIQ
PanelQMEMed-legalDenied

Michael Carrasco — ADJ10287483, ADJ10137345

MICHAEL CARRASCO, Applicant vs. UC DAVIS POLICE DEPARTMENT; CITY OF SACRAMENTO, Defendants

ADJ number
ADJ10287483, ADJ10137345
Decision date
Aug 4, 2022
District office
Sacramento
WCJ
Eric Ledger
Claim administrator
—
Commissioners
—

Injury / body parts: heart, circulatory system

LC §5412LC §3212.5LC §3212LC §5500.5LC §5705LC §3202.5LC §3600

Summary

Applicant Michael Carrasco, a career police officer, claimed industrial injury to his heart and circulatory system across two employers: a cumulative trauma claim against City of Sacramento (ending October 4, 2013) and a specific injury claim against UC Davis Police Department (September 10, 2015). The WCJ found applicant qualified for the heart presumption under Labor Code section 3212.5 against City of Sacramento, found industrial injury, and apportioned 50% to each employer based on QME reporting from Dr. Bellinger and Dr. Levy. City of Sacramento petitioned for reconsideration, arguing it had rebutted the presumption either because the sarcoidosis-based heart condition was non-industrial or because the UC Davis injury was the sole cause. The WCAB adopted and incorporated the WCJ's report, holding that concurrent causation alone does not rebut the presumption and that the cause of applicant's sarcoidosis was unknown to science—so defendant could not prove it was non-industrial. Reconsideration was denied.

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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