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PanelQMEMed-legalGranted in Part

Jeffrey Blake — ADJ11253479

JEFFREY BLAKE, Applicant vs. STATE OF CALIFORNIA, Legally Uninsured, Defendant

ADJ number: ADJ11253479
Decision date: Jul 9, 2026
District office: Goleta
WCJ: —
Claim administrator: State Compensation Insurance Fund
Commissioners: KATHERINE A. ZALEWSKI, CHAIR, JOSEPH V. CAPURRO, COMMISSIONER, PAUL F. KELLY, COMMISSIONER

Injury / body parts: neck/cervical spine, psyche, head, headaches

LC §4660.1LC §4664LC §4663LC §5909LC §5900LC §3208.3

Summary

Jeffrey Blake, a DMV examiner, sustained injury to his neck, psyche, head, and headaches in a February 3, 2017 motor vehicle accident where the vehicle bottomed out at high speed, causing him to strike his head twice, eventually requiring spinal fusion. The WCJ awarded 72% permanent disability, applying the violent-act exception to Labor Code section 4660.1(c), finding no apportionment, adding rather than combining disabilities, and including a separate 3% headache pain add-on. The Appeals Board granted reconsideration and reduced the award to 47%, finding the WCJ erred in failing to incorporate Dr. Newton's section 4663 apportionment (40% of cervical disability to pre-existing factors) and in improperly adding a second Chapter 18 pain add-on for headaches. The Board affirmed the violent-act exception for psychiatric PD, rejected section 4664 apportionment for lack of proven overlap, and affirmed the Kite/Vigil addition of psychiatric and orthopedic impairments due to synergy.

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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Similar decisions

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Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.