County of Monterey, PSI, Helmsman Management Services v. Workers' Compensation Appeals Board

In County of Monterey, PSI, Helmsman Management Services v. Workers' Compensation Appeals Board (2000) 65 Cal.Comp.Cases 853, the applicant suffered a bilateral wrist injury in 1994. The psychiatric evaluator apportioned 60 percent of her psychiatric injury to the industrial injury, assuming the loss of medical insurance resulting from her absence from work was a compensable consequence of the wrist injury. If not, he apportioned 50 percent of the psychiatric injury to industrial factors. The WCJ found the loss of insurance was nonindustrial, and 50 percent industrial causation did not meet the statutory threshold. The Board granted reconsideration and rescinded the WCJ's finding based on " 'the principle of compensable consequences, as applied in the Rebelo and Bechtel cases' " (id. at p. 855), i.e., section 3208.3 does not apply to a claim of psychiatric disability resulting from physical industrial injury.