Authorities as the decision cited them, with how this panel applied each one.
McAllister v. Workers' Comp. Appeals Bd. (1968) 33 Cal. Comp. Cases 660; Rosas v. Workers' Comp. Appeals Bd. (1993) 58 Cal. Comp. Cases 313; South Coast Framing v. Workers' Comp. Appeals Bd. (Clark) (2015) 80 Cal. Comp. Cases 489
An applicant must show industrial causation is reasonably probable and work was a contributing cause.
Applied to determine compensability of death as a consequence of industrial injury.
From the decision · page 5An applicant is not required to prove the existence of an industrial injury beyond a reasonable
doubt. Instead, an applicant merely needs to present substantial evidence showing that "industrial
causation is reasonably probable" [McAllister v. Workers' Comp. Appeals Bd. (1968) 33 Cal.
Comp. Cases 660, 665; Rosas v. Workers' Comp. Appeals Bd. (1993) 58 Cal. Comp. Cases 313,
322] and that work was a "contributing cause." [South Coast Framing v. Workers' Comp. Appeals
Bd. (Clark) (2015) 80 Cal. Comp. Cases 489, 495]
Laines v. Workmen's Comp. Appeals Bd. (1975) 40 Cal Comp. Cases 365
Injury sustained en route to medical treatment for industrial injury is compensable if visit is based on statutory obligation.
Applied to find injury en route to medical treatment compensable.
From the decision · page 6"Where the visit to the doctor is based on the statutory obligation of the
employer to furnish and the employee to submit to medical examination and
nondangerous treatment, an injury sustained in the course of such a visit
should be held to be an injury arising out of and in the course of employment
within the meaning of [] 3600 of the Labor Code." [Laines v. Workmen's
Comp. Appeals Bd. (1975) 40 Cal Comp. Cases 365, 369 (internal citations
omitted.)]
Beaty v. Workers' Comp. Appeals Bd. (1978) 43 Cal. Comp. Cases 444
Subsequent injury is compensable consequence if industrial injury was a contributing factor.
Applied to find the fatal accident a compensable consequence of the industrial injury.
From the decision · page 5In addition, a subsequent injury will constitute a compensable consequence of an industrial injury
if the industrial injury was a contributing factor in the occurrence of the subsequent injury. [Beaty
v. Workers' Comp. Appeals Bd. (1978) 43 Cal. Comp. Cases 444, 448]
Sutter Solano Medical Center v. Workers' Comp. Appeals Bd. (2018); Barela v. Leprino Foods (2009)
Treatment need not be authorized to be compensable if it cures or relieves effects of industrial injury.
Applied to find self-procured treatment compensable.