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claimant did not satisfy her burden of establishing that she sustained a compensable industrial injury where her entire psychiatric disability was not predominantly work induced. 

In Sonoma State Univ. v. WCAB, 142 Cal. App. 4th 500 (Cal. App. 1st Dist. 2006),  a police dispatcher for a university filed a workers’ compensation claim for “an injury to her psyche arising out of and in the course of her employment.” She alleged that the injury resulted from cumulative trauma.

An agreed medical evaluator (AME) examined the claimant and reported that the claimant stated that her job was stressful due to frequent and unexpected false fire and burglar alarms. The AME reported that other events and circumstances in her life also contributed to her difficulties.

The AME diagnosed her as suffering from an adjustment disorder that was “Industrially Caused.” At issue before the workers’ compensation judge (WCJ) was whether the claimant had satisfied her burden of establishing a compensable industrial injury.  She had to prove that her psychological injury was “predominantly caused by actual events of employment.” The WCJ found the claimant had met that burden and the WCAB upheld the decision of the WCJ. Concluding that a psychiatric injury could not be “parsed into separately diagnosable components” to satisfy the threshold requirement, the appellate court annulled the WCAB’s decision.