Shannon v. Workers' Compensation Appeals Board

In Shannon v. Workers' Compensation Appeals Board (1997) 62 Cal.Comp.Cases 1462, it ruled that a psychiatric injury arising from a 1992 industrial foot injury did not satisfy the statute's threshold of compensability. Even though the applicable version of subdivision (d) contained the later-deleted language excluding psychiatric compensable consequences claims from the section's purview, the Board "was not persuaded that subdivision (d) invalidated the higher threshold of compensability set forth in subdivisions (b) and (c), because that would defeat the purpose of the statute." ( Shannon, supra, 62 Cal.Comp.Cases at p. 1464, )