Julio Ramirez (Dec.) — ADJ13315589

Julio Ramirez, an executive sales representative who traveled to Kentucky and Indiana for jewelry trunk shows in early March 2020, returned to Los Angeles on March 8, 2020, developed COVID-19-like symptoms, and died on March 16, 2020. An autopsy concluded he died of acute viral pneumonia 'likely due to COVID-19.' The WCJ found the death arose out of and in the course of employment, but defendant sought reconsideration arguing there was no substantial evidence the spouse was infected at work or that any infection was employment-related. The Board agreed the record lacked substantial medical evidence on AOE/COE because the only medical report (the autopsy) addressed cause of death but not industrial causation, and neither the section 3212.86 nor 3212.88 COVID presumptions applied. The Board granted reconsideration, rescinded the F&O, and remanded for development of the record, recommending an epidemiologist AME or regular physician address exposure risk and causation.