WCPanelIQ
PanelMed-legalGranted

Patricia Delph — ADJ10362589, ADJ12575343, ADJ12575772, ADJ12561678

PATRICIA DELPH, Applicant vs. SCRIPPS HEALTH; permissibly self-insured, administered by SEDGWICK RIVERSIDE; PALOMAR HEALTH, permissibly self-insured, administered by ATHENS ADMINISTRATORS ORANGE, Defendants

ADJ number
ADJ10362589, ADJ12575343, ADJ12575772, ADJ12561678
Decision date
May 17, 2026
District office
San Diego
WCJ
—
Claim administrator
Sedgwick Riverside (for Scripps Health); Athens Administrators Orange (for Palomar Health)
Commissioners
CRAIG L. SNELLINGS, COMMISSIONER, KATHERINE A. ZALEWSKI, CHAIR, JOSÉ H. RAZO, COMMISSIONER

Injury / body parts: knee, back, spine (lumbar fusion/spinal cage)

LC §5950LC §5909LC §5900LC §5903LC §5952LC §4060LC §4061LC §4062.3LC §5907LC §5908LC §5908.5LC §5803LC §5901LC §5272CCR §10600

Summary

In this multi-defendant contribution dispute arising from Patricia Delph's industrial injuries while employed at Scripps Health and Palomar Health, a workers' compensation arbitrator (WCA) found a significant specific injury on January 13, 2015 (apportioned 60%) and a single compensable cumulative trauma through September 20, 2016 (apportioned 40%), rejecting two other alleged CT periods. The WCA acknowledged 'blending' the medical opinions of Drs. Tontz and Bernicker within the range of evidence to reach his apportionment and granted Scripps' Petition for Contribution. Scripps sought reconsideration, arguing the decision was not based on substantial medical evidence because the WCA relied on a 'blend' of evidence. The Appeals Board granted reconsideration, finding it unclear on preliminary review that substantial medical evidence supported the WCA's causation determination without further development of the record. The Board deferred issuance of a final decision pending further review of the merits and the entire record.

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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