Soledad Garcia — ADJ9618682

Applicant Soledad Garcia was struck from behind by a forklift in 2014, sustaining multiple orthopedic and other injuries while employed as an extractor. The WCJ found injuries AOE/COE to numerous body parts and 64% permanent disability, but denied industrial causation for Parkinson's disease and rejected the violent act exception for psychiatric impairment. On reconsideration, the WCAB agreed Parkinson's was not industrial and that the forklift incident did not qualify as a 'violent act' under section 4660.1(c)(2)(A), but found that the psychiatric QME (Dr. Jacks) split causation between a direct psychiatric injury and a compensable consequence injury that, combined, may meet the predominant causation threshold of section 3208.3(b)(1). The Board rescinded the F&A and remanded for development of the record to clarify Dr. Jacks' causation and apportionment opinions, and directed inclusion of impairment for headaches, disfigurement, and right leg pain (but not sleep, which was not pled).