Strom, Bryce

Applicant Bryce Strom, an apprentice ironworker, sustained admitted industrial injuries on April 4, 2022, when he slipped while working harnessed on the fourth floor, swung pendulum-style into a metal column, and struck his head, suffering a traumatic brain injury with hemorrhagic contusion. The WCJ found that applicant's injury was neither a violent act nor a catastrophic injury under Labor Code sections 4660.1 and 3208.3, denying increased permanent disability for the psyche and erectile dysfunction claims. The Appeals Board granted reconsideration, rescinded the F&O, and remanded, holding that the WCJ erroneously applied a requirement that a violent act involve a force 'outside the applicant's own body' and that, even under that flawed standard, applicant's injury was caused by outside forces (the harness, cable, and metal column). The Board further found the WCJ conflated the violent act and catastrophic injury analyses and failed to fully evaluate all medical evidence under the Wilson factors. The Board concluded the record required further development to determine what portion of applicant's symptoms were attributable to a physical brain injury versus a direct or compensable consequence psychiatric injury. Commissioner Razo dissented, finding the record adequate and the WCJ's conclusions supportable.