Jose Luis Valencia — ADJ13633820

Applicant Jose Luis Valencia sustained a cumulative trauma injury (2019-2020) as a driver affecting multiple body parts. After the WCJ found 100% permanent total disability based on the vocational reporting of applicant's expert Enrique Vega, defendant sought reconsideration, arguing Vega's report was not substantial evidence because it relied on functional limitations not found in the PQME reports and rendered improper medical opinions, and that the record needed development because the PQME did not review the vocational reports. The WCAB denied reconsideration, holding Vega's report constituted substantial evidence because his real-time observations during vocational testing fell within the scope of vocational assessment, while defendant's expert Nick Corso improperly evaluated a hypothetical worker by inflating applicant's aptitude and language baselines to average levels. The Board also rejected the request to develop the record and declined to reopen apportionment, finding defendant failed to meet its burden of proving apportionment.