Sonoma State University v. Workers' Compensation Appeals Board

Workers’ compensation law provides that a psychiatric injury is not compensable unless the employee can demonstrate that events of employment “were predominant as to all causes combined of the psychiatric injury.” (Lab. Code, § 3208.3, subd. (b)(1).) The question presented by this case is whether an employee’s psychiatric injury meets the threshold for compensability where the entire psychiatric disability is not predominantly work induced but where one (or more) of several diagnosed psychiatric conditions is entirely (or predominantly) work induced. We conclude that a psychiatric injury cannot be parsed into separately diagnosable components for purposes of satisfying the standard set forth in section 3208.3.

I. FACTS AND PROCEDURAL BACKGROUND

Respondent Lesley Hunton began working as a police dispatcher for Sonoma State University in 1986. Hunton filed a workers’ compensation claim in 2000 alleging an injury to her psyche arising out of and in the course of her employment with petitioner Sonoma State. Hunton alleged the injury resulted from cumulative trauma through August 2000.

An agreed medical evaluator (AME) examined Hunton in 2004. Hunton told the AME her job…