Sharon Hughes — ADJ12141593, ADJ2333041

Sharon Hughes sustained an industrial injury on March 20, 2019 while working as an organizer for Groundworks Campaigns, settling her underlying claim via C&R. She then sought SIBTF benefits, alleging preexisting permanent partial disability. The WCJ initially found applicant failed to prove preexisting permanent partial disability and ordered her to take nothing. On reconsideration, the Board found the trial issues improperly conflated apportionment with preexisting permanent disability under the Todd framework, and that PQME Cortes's history of prior labor-disabling injuries (1997 carpal tunnel and 2002 rotator cuff) was substantial evidence of a labor-disabling restriction, while Dr. Minkstein's reporting was not substantial. The Board rescinded the F&O, deferred the issue of preexisting permanent disability of the bilateral wrists/hands and right shoulder along with all other SIBTF eligibility issues, and remanded for further development of the record.