Sonoma State Univ. v. WCAB, 142 Cal. App. 4th 500 (2006)

Lesley Hunton worked as a police dispatcher for Sonoma State University for 14 years before filing a workers’ compensation claim in which she alleged an injury to her psyche arising out of and in the course of her employment. Hunton complained that the frequent and unexpected sounding of false fire and burglar alarms in the work place was causing her to suffer from stress and anxiety. An agreed medical evaluator determined that 65% of Hunton’s psychiatric disability was attributable to non-industrial factors and that the remaining 35% was attributable to industrial factors. Although the WCAB upheld the decision of the workers’ compensation judge to grant benefits to Hunton because 100% of one of her disorders was work-related, the Court of Appeal reversed, holding that events of employment must predominate in the aggregate among all combined causes of an alleged psychiatric disability. Cf. JKH Enterprises, Inc. v. Department of Indus. Relations, 2006 WL 2412270 (Cal. Ct. App. 2006) (courier service was properly assessed penalty of $1,000 per employee for failure to provide workers’ compensation coverage to drivers who were improperly classified as “independent contractors”).