Everett Rice — ADJ11317555

Applicant Everett Rice, an associate buyer, claimed a psychiatric injury (Major Depressive Disorder) from a cumulative trauma period of May 10, 2017 through May 10, 2018. The WCJ found the claim barred under Labor Code section 3208.3(h), concluding the psychiatric injury was substantially caused by lawful, nondiscriminatory, good faith personnel actions. The WCAB granted reconsideration and rescinded the F&O, holding that the QME, Dr. Yassi Zarrin, failed to identify each individual event of employment and assign corresponding percentages of causation, rendering the Rolda analysis incomplete. The Board also noted the date of injury under section 5412 was not established and that claims for 'stress' and nervous system injury are not psychiatric injuries subject to section 3208.3. The matter was remanded for development of the record and further proceedings.