Donna Larson vs. STATE OF CALIFORNIA, DEPARTMENT OF CORRECTIONS, Legally Uninsured, SCIF STATE EMPLOYEES ROHNERT PARK, Adjusting Agency

The Workers' Compensation Appeals Board granted reconsideration to clarify the Administrative Law Judge's (ALJ) findings on applicant Donna Larson's psychiatric injury. The ALJ found Larson sustained cumulative trauma injury to her circulatory system and psyche, with ongoing temporary disability. Defendant argued the psychiatric injury finding was unsubstantiated, particularly regarding whether actual employment events were the predominant cause and if lawful personnel actions were a substantial cause. The Board found the ALJ's analysis under Labor Code section 3208.3 and the Rolda case lacked sufficient clarity regarding the predominant cause of the psychiatric injury and the impact of lawful personnel actions, including the applicant's termination. Therefore, the case was remanded to the trial level for further proceedings and a new decision to clarify these critical legal standards.