Michael Snowden — ADJ11027260

Applicant Michael Snowden, a Los Angeles police officer, suffered a cerebrovascular accident (stroke) in August 2017 while visiting his brother in Colorado. The WCJ found industrial injury to the brain, heart and neurological system, applying the heart trouble presumption of Labor Code section 3212.5 and finding defendant had not rebutted it. Defendant, the permissibly self-insured City of Los Angeles, sought reconsideration arguing applicant's congenital patent foramen ovale (PFO) and personal travel were the sole nonindustrial causes of the stroke. The WCAB affirmed, holding that defendant failed to prove a contemporaneous nonwork-related event was the sole cause because the stroke required the convergence of multiple factors including the presumptively industrial PFO, which manifested for the first time during the injury and thus could not be attributed to a preexisting disease under the anti-attribution clause.