Roberto Orozco — ADJ13514341

Applicant Roberto Orozco sustained a cumulative trauma injury (March 25, 2017 through March 25, 2020) to his left hip, right knee, and lumbar spine while working as a construction laborer. Based on PQME Dr. Rommel Hindocha's reports and deposition testimony, the WCJ found 71% permanent disability by adding rather than combining impairments under the Combined Values Chart (CVC), consistent with Vigil v. County of Kern. Defendant petitioned for reconsideration, arguing the addition of impairments was not supported by substantial medical evidence, was not permitted under the AMA Guides, and was precluded by Fitzpatrick. The Appeals Board denied reconsideration, holding that Dr. Hindocha's reporting adequately rebutted the CVC by demonstrating the impact of each impairment on ADLs, that the AMA Guides expressly recognize addition may be appropriate, and that Fitzpatrick does not preclude application of Vigil.