Peter Manis — ADJ10848254

Applicant Peter Manis, a Google software engineer, claimed a cumulative psychiatric injury for the period May 6, 2015 through May 6, 2016. Psychology QME Dr. Shawn Fruge found that applicant's pre-existing psychiatric disorders were predominantly (greater than 50%) aggravated by actual events of employment, and identified four specific management behaviors as causative. The WCJ found injury AOE/COE based on Dr. Fruge's reports and deposition testimony, and defendant sought reconsideration arguing the QME reports did not constitute substantial evidence and that aggravation of only 'part' of a pre-existing condition was insufficient. The WCAB denied reconsideration, holding that the industrial aggravation of a pre-existing condition constitutes a compensable injury and that Dr. Fruge's well-reasoned opinions met the substantial evidence standard. The Board also addressed timeliness under the Shipley doctrine, finding the 60-day period ran from actual notice to the Board on July 7, 2021.