Debbie Chadburn — ADJ1351389, ADJ7168611, ADJ7183596

Debbie Chadburn was awarded 100 percent permanent total disability by the WCJ in his Second Amended Findings and Award of September 22, 2017, which the WCAB affirmed on June 17, 2019 with an unapportioned award. The Sixth District Court of Appeal annulled the WCAB's decision, holding that the psychiatric reports relied upon (Dr. Sidle) did not constitute substantial evidence because they rested on the 'alternative path theory' rejected in Fitzpatrick, and that applicant's evidence was otherwise insufficient to rebut the scheduled rating for her psychiatric disability. The Court also gave guidance on apportionment, the Benson 'limited circumstances' exception permitting a single combined award, and joint and several awards of medical treatment subject to later apportionment between carriers. On remittitur, the WCAB granted reconsideration, rescinded the WCJ's Second Amended Findings and Award, and returned the matter to the trial level for new Findings and Award consistent with the appellate opinion. The Court otherwise affirmed the WCJ's prior findings, which may be re-issued.