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PanelQMEMed-legalDenied

Lara, Hadrian

HADRIAN LARA, Applicant vs. SUBEQUENT INJURIES BENEFITS TRUST FUND, et. al., Defendants

ADJ number: ADJ7937623
Decision date: Jun 26, 2025
District office: Van Nuys
WCJ: —
Claim administrator: —
Commissioners: JOSEPH V. CAPURRO, COMMISSIONER, JOSÉ H. RAZO, COMMISSIONER, ANNE SCHMITZ, DEPUTY COMMISSIONER

Injury / body parts: cervical spine, lumbar spine, bilateral shoulders, bilateral wrists, bilateral hands, psyche, sleep/arousal, hypertension/cardiovascular, digestive tract (GERD, IBS, acid peptic disease)

LC §4751LC §3202.5LC §4663LC §4664

Summary

Applicant Hadrian Lara sought benefits from the Subsequent Injuries Benefits Trust Fund (SIBTF), arguing that the 70% non-industrial apportionment of his hypertension established a pre-existing permanent partial disability under Labor Code section 4751. The WCJ found he failed to prove a pre-existing labor-disabling disability and ordered him to take nothing. The Board affirmed, holding that apportionment to non-industrial factors does not automatically establish that the disability pre-existed the subsequent industrial injury. Following Escobedo and Todd, the Board emphasized that a pre-existing condition must have been labor disabling before the subsequent injury, and this must be demonstrated through medical evidence rather than presumed from an apportionment finding.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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Similar decisions

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Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.