California WCABLaw firm

Brown & Delzell

Brown & Delzell is named in 22 released California WCAB decisions from 2021–2026. The disputes run to AOE/COE (6), Temporary disability (6) and Permanent disability rating (3). They were heard most often at San Francisco, then Santa Rosa.

Decisions: 22
Years: 2021–2026
Issues disputed: 10
District offices: 7

What they litigate

Disputed issues across the decisions this firm is named in. Every row opens the decisions it counts.

By disputed issue

Decisions naming this firm, counted by what was in dispute.

AOE/COE
626%
Temporary disability
626%
Permanent disability rating
313%
Jurisdiction / venue
29%
QME/AME process
29%
Medical treatment / UR / IMR
29%
Apportionment
14%
Discrimination under Labor Code §132a
14%

23 decisions across the groups shown

Who they face

We could not read this firm’s own side from the record, so there is no other side to name.

Carriers and administrators

Where they appear

San Francisco 14
Santa Rosa 3
Eureka 1
Los Angeles 1
Oakland 1
Redding 1
Sacramento 1

How the appealed decisions came out

These are decisions that were appealed and published — the tail of a system that mostly settles. Most claims end in a compromise and release or a stipulation and never reach a panel, so nothing below describes how this firm does its work. It describes how a set of appealed disputes came out.

14 for the applicant
5 for the defense
3 returned for more record

Counted over 20 appealed decisions. Not this firm’s book of work. A decision that went one way on one issue and the other way on another is counted in both columns, so the figures add up to more than the total.

Decisions

Newest decisions this firm is named in, each with the passage the panel turned on and a link to the official PDF.

ADJ22856965 · 2026-09-08 · San Francisco District OfficeTemporary disabilityapplicant prevailed
Determinative passage · p.4Turning to the merits, with regard to entitlement to temporary disability benefits beyond August 14, 2024, applicant essentially argues that defendant is estopped from relying on the permanent and stationary date in Dr. Feinberg’s report because defendant ignored Dr. Feinberg’s repeated opinion that applicant sustained industrial injury and compensable disability. 4 While we appreciate applicant’s rhetorical flourish, our decision must be based on the evidence in the record, and we have no power to punitively create further temporary disability because of unreasonable delays or bad faith litigation tactics. The Labor Code provides other remedies for this type of conduct (see, e.g., Lab. Code, §§ 5813, 5814). “[T]emporary disability indemnity is payable during the injured worker’s healing period from the injury until the worker has recovered sufficiently to return to work, or until his/her condition reaches a permanent and stationary status.” (Huston v. Workers’ Comp. Appeals Bd. (1979) 95 Cal.App.3d 856, 868 [44 Cal.Comp.Cases 798].) Here, Dr. Feinberg opined that applicant’s condition reached permanent and stationary status on August 13, 2024.
Official decision · page 4 →
ADJ16340745 · 2026-08-07 · San Francisco District OfficeMedical treatment / UR / IMRapplicant prevailed
Determinative passage · p.1Defendant City and County of San Francisco seeks reconsideration of the Findings of Fact and Award (F&A) issued by a workers’ compensation arbitrator (WCA) on April 27, 2026. In that decision, the WCA found, in relevant part, that applicant could self-procure medical treatment without going through the employer’s Medical Provider Network (MPN) or making a demand on defendant for the treatment, and that the disc replacement surgery that applicant self-procured, was reasonable and necessary, and should be reimbursed by defendant, based upon the medical report of Independent Medical Evaluator (IME) Steven Feinberg, M.D.
The WCA found that defendant neglected to provide reasonable medical care through the MPN and failed to provide required notice of rights, enabling applicant to self-procure surgery which was reasonable and necessary, thus awarding reimbursement.
Official decision · page 1 →
ADJ8833300 · 2026-07-31 · San Francisco District OfficeDiscrimination under Labor Code §132aremanded
Determinative passage · p.1Applicant sought reconsideration of the Findings and Order issued on June 16, 2021, by a workers’ compensation administrative law judge (WCJ). The WCJ found, in pertinent part, that defendant did not violate Labor Code section 132a and ordered that applicant take nothing by way of his Labor Code section 132a petition. Applicant contends that he met his burden to establish a prima facie claim that defendant violated Labor Code section 132a and that defendant did not meet its burden to show a reasonable business necessity for its actions. We have received an Answer from defendant. We received a Report and Recommendation on Petition for Reconsideration (Report) from the WCJ, recommending that we deny reconsideration. We issued an order granting reconsideration pending further review of the entire record. 1 Thereafter, the parties successfully participated in voluntary mediation at the Appeals Board. Subsequently, the parties advised that a proposed settlement had been reached. In order to expedite review and approval of the parties’ settlement agreement, we will rescind the June 16, 2021 Findings and Order and return this matter to the trial level to consider the settlement. The assigned WCJ may conduct such further proceedings as is deemed appropriate.
The WCJ found no violation of Labor Code section 132a and the Appeals Board did not rule on the merits but rescinded the prior order and returned the matter for settlement consideration.
Official decision · page 1 →
ADJ12492033 · 2026-05-15 · San Francisco District OfficeAOE/COEapplicant prevailed
Determinative passage · p.1Defendant City and County of San Francisco seeks reconsideration of the Opinion on Decision and Findings (OD & F) issued on November 14, 2025, wherein a workers' compensation arbitrator (WCA) found that applicant sustained an injury arising out of an occurring in the course of his employment (AOE/COE) to his left hand, a needlestick injury, and injury in the form of blood and Hematopoietic Purpura (ITP).
The Arbitrator found the opinion of the primary treating physician Dr. Savage, that the applicant's ITP was caused by the needle stick injury and subsequent medication, to be better reasoned and more persuasive than the QME's contrary opinion, supported by credible testimony and medical evidence showing symptoms immediately after medication and no intervening cause.
Official decision · page 1 →
ADJ15918599 · 2026-04-07 · Santa Rosa District OfficeAOE/COEapplicant prevailed
Determinative passage · p.5Doctor Fishman also stated his opinion that applicant's cancer was a "insidious, progressive disease" warranting the extension of the Board's jurisdiction beyond the 5-year statute of limitations set forth in Labor Code § 5410 pursuant to General Foundry Service v. WCAB (Jackson), (1986) 42 C3d 331. He states:
Medical evidence showed applicant's kidney cancer is a progressive, insidious disease with potential for recurrence, justifying extension of jurisdiction beyond the 5-year statute of limitations.
Official decision · page 5 →
ADJ11221216 · 2026-03-23 · Redding District OfficePermanent disability ratingapplicant prevailed
Determinative passage · p.1Defendant seeks reconsideration of the Findings of Fact, Award issued by the workers' compensation administrative law judge (WCJ) on December 29, 2025. Therein, and as relevant here, the WCJ found that applicant sustained admitted injury arising out of and occurring in the course of employment (AOE/COE) to the psyche while employed as a patrol officer during the period to and including November 5, 2017. The WCJ further found that applicant "cannot benefit from the provision of rehabilitation, as his restrictions from the industrial injury render him unable to compete for work in the general labor market. Therefore, he is found to be totally permanently disabled."
The WCJ's finding of total permanent disability was upheld because the defendant failed to provide substantial medical evidence to support apportionment, and the vocational evidence showed the applicant could not compete in the open labor market.
Official decision · page 1 →
ADJ13057169 · 2026-03-12 · San Francisco District OfficePermanent disability ratingapplicant prevailed
Determinative passage · p.8Defendant contends that the WCJ's adoption of Dr. Burt's Almaraz-Guzman rating was an "improper deviation from the permanent disability rating schedule." (Petition, p. 10.)
The WCJ's adoption of Dr. Burt's Almaraz-Guzman rating was supported by substantial medical evidence, including a thorough explanation of the alternative rating method and the synergistic effect of multiple injuries, consistent with Almaraz-Guzman II and Vigil standards.
Official decision · page 8 →
ADJ18001417 · 2025-09-05 · San Francisco District OfficeAOE/COEapplicant prevailed
Determinative passage · p.6The issue here is injury AOE/COE. Applicant has two avenues by which to prove this. If his meningioma is or shows signs of malignancy, then he comes within the cancer presumption of Labor Code sec. 3212.1. Alternatively, his injury is compensable if there is evidence that applicant's exposure to toxins, carcinogens, smoke and other substances during his employment caused, contributed to or accelerated the growth of the meningioma.
The Board found the applicant's meningioma to be Grade II based on the treating neurosurgeon's opinion, which was more substantial than the IME's Grade I opinion. The cancer presumption under Labor Code section 3212.1 applies, making the injury compensable.
Official decision · page 6 →
ADJ10774716 · 2025-09-02 · San Francisco District OfficePermanent disability ratingapplicant prevailed
Determinative passage · p.1Defendant seeks reconsideration of the Findings and Award (F&A), issued by the workers' compensation administrative law judge (WCJ) on June 2, 2025, wherein the WCJ found in pertinent part that applicant sustained injury arising out of and in the course of employment in the form of a stroke and to the psyche; that applicant's injury has resulted in permanent total disability; and that defendant has not met its burden of proof with regard to non-industrial apportionment.
The WCJ and WCAB found that the QME's apportionment opinion was not substantial evidence because it apportioned to causation of injury (stroke) rather than causation of disability, and did not explain how risk factors caused the disability. Therefore, the award of 100% permanent total disability without apportionment was upheld.
Official decision · page 1 →
ADJ16819535 · 2025-02-21 · Oakland District OfficeTemporary disabilityremanded
Determinative passage · p.7Accordingly, we will grant the Petition, and, as our Decision After Reconsideration, we will rescind the F&A and substitute findings that defer the issues of temporary disability and attorney's fees; and we will return the matter to the trial level for further proceedings consistent with this decision.
The issue of temporary disability and attorney's fees was deferred due to defendant being deprived of due process by admission of a medical report after discovery closed, requiring further discovery and hearing.
Official decision · page 7 →
ADJ14902030 · 2025-01-24 · San Francisco District OfficeAOE/COEapplicant prevailed
Determinative passage · p.1Defendant seeks reconsideration of the Joint Findings of Fact, Award, and Order (F&A) issued by a workers' compensation administrative law judge (WCJ) on October 16, 2024. In that decision, the WCJ found in pertinent part in Case No ADJ14902030 that applicant, while employed during the period of November 15, 2004 through January 23, 2021 as a firefighter by defendant the City of Daly City, sustained injury arising out of and in the course of employment to the respiratory system and circulatory system/heart and that applicant's injury caused permanent disability of 79% in Case No ADJ14902030, and she awarded permanent disability, attorney's fees, and a life pension; and in Case No. ADJ19260558 that applicant, while employed during the period of January 1, 2005 through January 23, 2021 as a firefighter, by the City of Daly City, did not sustain injury arising out of and in the course of employment to the circulatory system/heart and ordered that applicant take nothing in Case No. ADJ19260558.
The WCJ found that applicant's employment caused a single injury to the respiratory and circulatory system/heart, supported by medical evidence and employment history.
Official decision · page 1 →
ADJ16340745 · 2025-01-03 · San Francisco District OfficeStatute of limitationsapplicant prevailed
Determinative passage · p.1Defendant City and County of San Francisco seeks reconsideration of the Findings of Fact, Order and Award (F, O and A) filed by a workers' compensation arbitrator (WCA) on April 22, 2022. In that decision, the WCA found that applicant's claim for worker's compensation benefits is not barred by the one-year statute of limitations of Labor Code section1 5405 because the five- year statute of limitations of section 5410 applies to the facts of applicant's case. The WCA thereby made a finding, order, and award that applicant's claim was timely and allowed.
The applicant's claim was timely filed within the five-year statute of limitations under Labor Code section 5410 because the employer voluntarily furnished benefits, which tolled the one-year statute of limitations under section 5405 and triggered the five-year period for new and further disability claims.
Official decision · page 1 →

Also recorded as

The same firm is printed several ways across the decisions, and all of them were counted as one. This is every spelling behind the figures above.

BROWN & DELZELL, LLP
Brown & Delzell
BROWN & DELZELL
Brown & Delzell, LLP
BROWN DELZELL

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Brown & Delzell

Decisions

Years

2021–2026

Issues disputed

District offices

How the appealed decisions came out

14 for the applicant

5 for the defense

3 returned for more record

Decisions

Newest decisions this firm is named in, each with the passage the panel turned on and a link to the official PDF.

ADJ22856965 · 2026-09-08 · San Francisco District OfficeTemporary disabilityapplicant prevailed

Determinative passage · p.4Turning to the merits, with regard to entitlement to temporary disability benefits beyond August 14, 2024, applicant essentially argues that defendant is estopped from relying on the permanent and stationary date in Dr. Feinberg’s report because defendant ignored Dr. Feinberg’s repeated opinion that applicant sustained industrial injury and compensable disability. 4 While we appreciate applicant’s rhetorical flourish, our decision must be based on the evidence in the record, and we have no power to punitively create further temporary disability because of unreasonable delays or bad faith litigation tactics. The Labor Code provides other remedies for this type of conduct (see, e.g., Lab. Code, §§ 5813, 5814). “[T]emporary disability indemnity is payable during the injured worker’s healing period from the injury until the worker has recovered sufficiently to return to work, or until his/her condition reaches a permanent and stationary status.” (Huston v. Workers’ Comp. Appeals Bd. (1979) 95 Cal.App.3d 856, 868 [44 Cal.Comp.Cases 798].) Here, Dr. Feinberg opined that applicant’s condition reached permanent and stationary status on August 13, 2024.

Official decision · page 4 →

ADJ16340745 · 2026-08-07 · San Francisco District OfficeMedical treatment / UR / IMRapplicant prevailed

Determinative passage · p.1Defendant City and County of San Francisco seeks reconsideration of the Findings of Fact and Award (F&A) issued by a workers’ compensation arbitrator (WCA) on April 27, 2026. In that decision, the WCA found, in relevant part, that applicant could self-procure medical treatment without going through the employer’s Medical Provider Network (MPN) or making a demand on defendant for the treatment, and that the disc replacement surgery that applicant self-procured, was reasonable and necessary, and should be reimbursed by defendant, based upon the medical report of Independent Medical Evaluator (IME) Steven Feinberg, M.D.

The WCA found that defendant neglected to provide reasonable medical care through the MPN and failed to provide required notice of rights, enabling applicant to self-procure surgery which was reasonable and necessary, thus awarding reimbursement.

Official decision · page 1 →

ADJ8833300 · 2026-07-31 · San Francisco District OfficeDiscrimination under Labor Code §132aremanded

Determinative passage · p.1Applicant sought reconsideration of the Findings and Order issued on June 16, 2021, by a workers’ compensation administrative law judge (WCJ). The WCJ found, in pertinent part, that defendant did not violate Labor Code section 132a and ordered that applicant take nothing by way of his Labor Code section 132a petition. Applicant contends that he met his burden to establish a prima facie claim that defendant violated Labor Code section 132a and that defendant did not meet its burden to show a reasonable business necessity for its actions. We have received an Answer from defendant. We received a Report and Recommendation on Petition for Reconsideration (Report) from the WCJ, recommending that we deny reconsideration. We issued an order granting reconsideration pending further review of the entire record. 1 Thereafter, the parties successfully participated in voluntary mediation at the Appeals Board. Subsequently, the parties advised that a proposed settlement had been reached. In order to expedite review and approval of the parties’ settlement agreement, we will rescind the June 16, 2021 Findings and Order and return this matter to the trial level to consider the settlement. The assigned WCJ may conduct such further proceedings as is deemed appropriate.

The WCJ found no violation of Labor Code section 132a and the Appeals Board did not rule on the merits but rescinded the prior order and returned the matter for settlement consideration.

Official decision · page 1 →

ADJ12492033 · 2026-05-15 · San Francisco District OfficeAOE/COEapplicant prevailed

Determinative passage · p.1Defendant City and County of San Francisco seeks reconsideration of the Opinion on Decision and Findings (OD & F) issued on November 14, 2025, wherein a workers' compensation arbitrator (WCA) found that applicant sustained an injury arising out of an occurring in the course of his employment (AOE/COE) to his left hand, a needlestick injury, and injury in the form of blood and Hematopoietic Purpura (ITP).

The Arbitrator found the opinion of the primary treating physician Dr. Savage, that the applicant's ITP was caused by the needle stick injury and subsequent medication, to be better reasoned and more persuasive than the QME's contrary opinion, supported by credible testimony and medical evidence showing symptoms immediately after medication and no intervening cause.

Official decision · page 1 →

ADJ15918599 · 2026-04-07 · Santa Rosa District OfficeAOE/COEapplicant prevailed

Determinative passage · p.5Doctor Fishman also stated his opinion that applicant's cancer was a "insidious, progressive disease" warranting the extension of the Board's jurisdiction beyond the 5-year statute of limitations set forth in Labor Code § 5410 pursuant to General Foundry Service v. WCAB (Jackson), (1986) 42 C3d 331. He states:

Medical evidence showed applicant's kidney cancer is a progressive, insidious disease with potential for recurrence, justifying extension of jurisdiction beyond the 5-year statute of limitations.

Official decision · page 5 →

ADJ11221216 · 2026-03-23 · Redding District OfficePermanent disability ratingapplicant prevailed

Determinative passage · p.1Defendant seeks reconsideration of the Findings of Fact, Award issued by the workers' compensation administrative law judge (WCJ) on December 29, 2025. Therein, and as relevant here, the WCJ found that applicant sustained admitted injury arising out of and occurring in the course of employment (AOE/COE) to the psyche while employed as a patrol officer during the period to and including November 5, 2017. The WCJ further found that applicant "cannot benefit from the provision of rehabilitation, as his restrictions from the industrial injury render him unable to compete for work in the general labor market. Therefore, he is found to be totally permanently disabled."

The WCJ's finding of total permanent disability was upheld because the defendant failed to provide substantial medical evidence to support apportionment, and the vocational evidence showed the applicant could not compete in the open labor market.

Official decision · page 1 →

ADJ13057169 · 2026-03-12 · San Francisco District OfficePermanent disability ratingapplicant prevailed

Determinative passage · p.8Defendant contends that the WCJ's adoption of Dr. Burt's Almaraz-Guzman rating was an "improper deviation from the permanent disability rating schedule." (Petition, p. 10.)

The WCJ's adoption of Dr. Burt's Almaraz-Guzman rating was supported by substantial medical evidence, including a thorough explanation of the alternative rating method and the synergistic effect of multiple injuries, consistent with Almaraz-Guzman II and Vigil standards.

Official decision · page 8 →

ADJ18001417 · 2025-09-05 · San Francisco District OfficeAOE/COEapplicant prevailed

Determinative passage · p.6The issue here is injury AOE/COE. Applicant has two avenues by which to prove this. If his meningioma is or shows signs of malignancy, then he comes within the cancer presumption of Labor Code sec. 3212.1. Alternatively, his injury is compensable if there is evidence that applicant's exposure to toxins, carcinogens, smoke and other substances during his employment caused, contributed to or accelerated the growth of the meningioma.

The Board found the applicant's meningioma to be Grade II based on the treating neurosurgeon's opinion, which was more substantial than the IME's Grade I opinion. The cancer presumption under Labor Code section 3212.1 applies, making the injury compensable.

Official decision · page 6 →

ADJ10774716 · 2025-09-02 · San Francisco District OfficePermanent disability ratingapplicant prevailed

Determinative passage · p.1Defendant seeks reconsideration of the Findings and Award (F&A), issued by the workers' compensation administrative law judge (WCJ) on June 2, 2025, wherein the WCJ found in pertinent part that applicant sustained injury arising out of and in the course of employment in the form of a stroke and to the psyche; that applicant's injury has resulted in permanent total disability; and that defendant has not met its burden of proof with regard to non-industrial apportionment.

The WCJ and WCAB found that the QME's apportionment opinion was not substantial evidence because it apportioned to causation of injury (stroke) rather than causation of disability, and did not explain how risk factors caused the disability. Therefore, the award of 100% permanent total disability without apportionment was upheld.

Official decision · page 1 →

ADJ16819535 · 2025-02-21 · Oakland District OfficeTemporary disabilityremanded

Determinative passage · p.7Accordingly, we will grant the Petition, and, as our Decision After Reconsideration, we will rescind the F&A and substitute findings that defer the issues of temporary disability and attorney's fees; and we will return the matter to the trial level for further proceedings consistent with this decision.

The issue of temporary disability and attorney's fees was deferred due to defendant being deprived of due process by admission of a medical report after discovery closed, requiring further discovery and hearing.

Official decision · page 7 →

ADJ14902030 · 2025-01-24 · San Francisco District OfficeAOE/COEapplicant prevailed

Determinative passage · p.1Defendant seeks reconsideration of the Joint Findings of Fact, Award, and Order (F&A) issued by a workers' compensation administrative law judge (WCJ) on October 16, 2024. In that decision, the WCJ found in pertinent part in Case No ADJ14902030 that applicant, while employed during the period of November 15, 2004 through January 23, 2021 as a firefighter by defendant the City of Daly City, sustained injury arising out of and in the course of employment to the respiratory system and circulatory system/heart and that applicant's injury caused permanent disability of 79% in Case No ADJ14902030, and she awarded permanent disability, attorney's fees, and a life pension; and in Case No. ADJ19260558 that applicant, while employed during the period of January 1, 2005 through January 23, 2021 as a firefighter, by the City of Daly City, did not sustain injury arising out of and in the course of employment to the circulatory system/heart and ordered that applicant take nothing in Case No. ADJ19260558.

The WCJ found that applicant's employment caused a single injury to the respiratory and circulatory system/heart, supported by medical evidence and employment history.

Official decision · page 1 →

ADJ16340745 · 2025-01-03 · San Francisco District OfficeStatute of limitationsapplicant prevailed

Determinative passage · p.1Defendant City and County of San Francisco seeks reconsideration of the Findings of Fact, Order and Award (F, O and A) filed by a workers' compensation arbitrator (WCA) on April 22, 2022. In that decision, the WCA found that applicant's claim for worker's compensation benefits is not barred by the one-year statute of limitations of Labor Code section1 5405 because the five- year statute of limitations of section 5410 applies to the facts of applicant's case. The WCA thereby made a finding, order, and award that applicant's claim was timely and allowed.

The applicant's claim was timely filed within the five-year statute of limitations under Labor Code section 5410 because the employer voluntarily furnished benefits, which tolled the one-year statute of limitations under section 5405 and triggered the five-year period for new and further disability claims.

Official decision · page 1 →