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PanelDenied

Eddy, Park

PARK EDDY, Applicant vs. ACTIVE CAPTIVE MANAGEMENT; ACCIDENT FUND INSURANCE COMPANY OF AMERICA, administered by UNITED WISCONSIN INSURANCE, Defendants

ADJ number: ADJ16748364
Decision date: Jun 17, 2025
District office: Santa Ana
WCJ: Jeremy Clifft
Claim administrator: United Wisconsin Insurance, administering for Accident Fund Insurance Company of America
Commissioners: —

Injury / body parts: cardiovascular system, brain, left upper extremity, left lower extremity, sleep disturbance (psyche/sleep)

LC §5909LC §5900LC §4600

Summary

Applicant Park Eddy, former president of Active Captive Management, suffered an industrial stroke and related injuries requiring 24-hour attendant care. After defendant authorized 24-hour daily care, the sole remaining issue was whether applicant's spouse could provide the overnight (non-skilled) home health care. The WCJ found the spouse capable and credible, having provided overnight care since applicant's March 2023 discharge, and held applicant could select his spouse as his overnight care provider. The WCAB denied defendant's Petition for Reconsideration, adopting the WCJ's report and opinion, affirming that family members may serve as paid home caregivers where there is a documented need and the family member is able to perform the required care.

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.