Applicant Arturo Madrid, a window technician, filed a cumulative trauma claim (bilateral shoulders, knees, neck, elbows, wrists) cumulative to October 9, 2023, involving two successive employers/insurers: Champion Windows (insured by Berkshire Hathaway) and BBSI (insured by Ace American, administered by Corvel). After BBSI/Ace accepted the shoulder claim while Berkshire denied the entire claim, applicant elected to proceed against BBSI/Ace under Labor Code section 5500.5(c), and the WCJ issued a joint and several award of TTD and found the disputed body parts industrial, reserving jurisdiction over contribution/liability between defendants. BBSI/Ace sought reconsideration, arguing the election should not have been allowed and that a new PQME supplemental report from Dr. Shiffman absolved it of liability. The Board granted reconsideration solely to amend the FA&O to find that the defendant's stipulation to the election was irrelevant (because no consent or stipulation is required for an election), but otherwise affirmed, holding the election against the last employer was proper.
Issues
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Holding
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Analysis
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Applicant takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Defense takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Provider takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Similar decisions
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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