WCPanelIQ
PanelMed-legalDenied

Ryan Moss — ADJ11931714

RYAN MOSS, Applicant vs. HOSPITAL BUSINESS SERVICES, INC./ PRIME HEALTHCARE SERVICES; SAFETY NATIONAL CASUALTY CORPORATION, adjusted by CORVEL CORPORATION, Defendants

ADJ number
ADJ11931714
Decision date
Jun 6, 2021
District office
Anaheim
WCJ
Nancy M. Gordon
Claim administrator
CorVel Corporation (administering for Safety National Casualty Corporation)
Commissioners
—

Injury / body parts: left shoulder, left arm, neck

LC §3600LC §5313

Summary

Applicant Ryan Moss, a medical biller/coder, suffered a seizure while seated at her work cubicle on 8/31/2018, fell to the ground, and dislocated her left shoulder. The WCJ found the shoulder injury compensable AOE/COE even though the underlying seizure was idiopathic and non-industrial. Defendant petitioned for reconsideration, arguing the WCJ erred by relying solely on Gideon and that the record lacked supporting medical evidence. The WCAB affirmed the December 16, 2020 Findings and Order, adopting the WCJ's report and relying on Employers Mutual v. IAC (Gideon), which holds that an injury from a fall onto the employer's premises is compensable even where the fall was caused by an idiopathic condition. The Board denied reconsideration.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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