Guadalupe Castillo — ADJ10925935, ADJ10925933

Applicant Guadalupe Castillo sustained two stipulated industrial injuries while working as an events operator for Alameda County Fair: a lumbar spine injury (9/3/2008, ADJ10925933) and a right shoulder injury (5/8/2015, ADJ10925935). Both parties sought reconsideration of the WCJ's September 12, 2022 Findings and Award. The key dispute was whether AME Dr. Garland's reporting constituted substantial medical evidence, particularly his erroneous application of a 3% pain add-on to a 0% whole person impairment rating for the right shoulder and an improperly included pain add-on for the lumbar spine. The Board held that a pain add-on cannot be applied to a 0% impairment rating under Blackledge, and that Dr. Garland's reporting on the shoulder was not substantial evidence. The Board deferred the issue of right shoulder permanent disability for further record development and amended the lumbar spine permanent disability from 25% to 20%.