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Tesfamariam, Samson

SAMSON TESFAMARIAM, Applicant vs. UNITED CONTINENTAL HOLDINGS, INC., doing business as UNITED AIRLINES, permissibly self-insured, administered by SEDGWICK CLAIMS MANAGEMENT SERVICES, Defendants

ADJ number: ADJ19551252
Decision date: Feb 26, 2026
District office: San Francisco
WCJ: Hillary R. Allyn
Claim administrator: Sedgwick Claims Management Services
Commissioners: —

Injury / body parts: low back, lumbar spine

LC §4663LC §4909LC §5909LC §5900LC §5806LC §5807LC §15LC §3202.5LC §4663(a)CCR §10600CCR §10555CCR §10628

Summary

Applicant Samson Tesfamariam sustained an admitted specific injury to his low back on March 11, 2024, while working as a ramp agent for United Airlines. The WCJ found 41% permanent partial disability, denied defendant's claim for non-industrial apportionment under Labor Code section 4663, denied defendant a credit for temporary disability overpayment from June 27 to July 25, 2025, and awarded future medical treatment. Defendant petitioned for reconsideration, challenging the apportionment finding, the denial of credit, and noting a clerical error referencing the left shoulder. The Appeals Board denied reconsideration, adopting the WCJ's Report and finding the QME's apportionment opinion conclusory and not substantial evidence, and that the equities did not support a credit for overpayment.

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.