Donna Nickell — ADJ8160195

Applicant Donna Nickell sustained a 2010 industrial injury to her left wrist with compensable psyche and CRPS consequences, resulting in an 89% permanent partial disability award with a life pension. At an expedited hearing on February 6, 2026, the parties stipulated to a fourth commutation of applicant's entire life pension entitlement, with the DEU instructed to calculate the present value and a 15-day objection period built in. The WCJ issued a $171,296.00 Award of Commutation on March 16, 2026 before the objection period had run and without evidence the DEU calculation was served on the parties. Defendant petitioned for reconsideration, arguing it was denied the opportunity to object and that applicant failed to prove substantial hardship. The Board granted reconsideration, rescinded the Award, and returned the matter to the trial level on due process grounds, while holding that the stipulation to commute (as opposed to the amount) remained binding and final.