Carol Laudonio — ADJ6680097

Applicant Carol Laudonio, a child support officer for the County of San Bernardino (permissibly self-insured), sustained a cumulative trauma injury to her bilateral wrists and elbows during 2007-2008, settled in 2012 by Stipulations for 21% PD. She timely filed a Petition to Reopen for new and further disability on August 28, 2013, alleging worsening and adding shoulders and neck, then filed an Amended Application on January 16, 2015 adding a psychiatric injury. The WCJ found a compensable consequence psychiatric injury resulting in 54% PD without apportionment, not barred by Labor Code section 5410 or 4660.1(c)(1). A divided WCAB affirmed, holding that the broad timely petition preserved jurisdiction and that evidence showed a demonstrable change in condition within five years. Commissioner Razo dissented, arguing there was no substantial evidence of psychiatric treatment or disability within the five-year period.