Pete Garza — ADJ10507939, ADJ9231232

Applicant Pete Garza filed cumulative trauma claims; the WCJ found industrial hernia injuries in two cases but denied his bilateral knee injury claim in ADJ10507939, finding no proof of industrial causation and suggesting the claim was also time-barred. The Appeals Board granted reconsideration of the knee finding only, treating the matter as a hybrid (final/interlocutory) decision. The Board found the WCJ's reasoning flawed because the Opinion on Decision did not adequately distinguish between failure of proof and a statute of limitations defense, and because an applicant is not charged with knowledge of a cumulative trauma claim absent medical confirmation that the condition was work-related. The Board held expert medical opinion was required to resolve causation and that the record needed further development. The Board affirmed the remainder of the February 5, 2020 decision (including the hernia findings) but amended ADJ10507939 to defer all knee-related issues and remanded for further proceedings.