JEFFERY BLUM vs. STATE OF CALIFORNIA, CALIFORNIA HIGHWAY PATROL, STATE COMPENSATION INSURANCE FUND, STATE CONTRACT SERVICES

This case involves an employer's petition for reconsideration of a workers' compensation award. The Appeals Board denied the petition, affirming the finding that the applicant sustained new and further permanent disability to his knees. The employer's arguments regarding apportionment for the lumbar spine and bias of the medical evaluator were rejected, as the lumbar spine issue was settled by prior stipulation and bias was not raised timely. The Board found the medical evaluator's opinions on knee impairment constituted substantial evidence, despite a functional capacity evaluation.