JAVIER TRUJILLO vs. GALPIN MOTORS, INCORPORATED, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION for ULLICO CASUALTY COMPANY, in liquidation, PREFERRED AUTO DEALERS SELF-INSURANCE PROGRAM

This case concerns CIGA's petition for reconsideration of a WCJ's decision regarding an applicant's cumulative trauma injury. CIGA contested the date of injury and the finding that PADSIP was not "other insurance." The WCAB denied CIGA's petition, affirming the WCJ's finding that the date of injury was December 21, 2010, when the applicant first became temporarily disabled. The Board clarified that modified work or medical treatment alone does not establish disability for the purpose of determining the date of injury under Labor Code section 5412.