Loan Kim Phan — ADJ19474979

Applicant Loan Kim Phan, a customer service representative for EDD, claimed a cumulative psychiatric injury from June 18, 2009 to March 1, 2024. The AME, Luigi Piciucco, Ph.D., opined that only 40% of her Axis I psychiatric conditions were caused by employment events, with 60% attributable to a pre-existing nonindustrial paranoid personality disorder, failing the predominant (greater than 50%) causation standard under Labor Code section 3208.3(b)(1). The WCJ found the injury noncompensable and the applicant sought reconsideration, arguing the AME report was not substantial medical evidence and that defendant's actions exceeded good-faith personnel actions under section 3208.3(h). The Appeals Board denied reconsideration, finding Dr. Piciucco's reporting constituted substantial medical evidence and that, because the predominant causation threshold was not met, the Rolda good-faith personnel action analysis never became necessary. A companion order corrected a clerical error (omission of the date of service) in the decision served October 16, 2026.