ADJ19102087 · August 25, 2026

The WCJ and Board found substantial medical evidence from QME Dr. Fischer that stress from decedent’s employment contributed to his sudden cardiac arrest and death, meeting the standard that employment need only be a contributing cause of death for compensability under Labor Code and case law. Defendant’s challenges to the medical evidence and applicant’s credibility were rejected.

From the decision · page 3This matter involves a claim for death benefits by the widow of an injured worker who sustained a sudden cardiac arrest and died on November 10, 2023 while at the place and during the period of his employment. (F&O, Opinion on Decision, p. 1.) While the QME in this case states that stress from decedent’s employment contributed to the cause of his sudden cardiac arrest and death, there is no claim for psychiatric injury. (See Applications for Adjudication of Claim- Death, April 8, 2024 and April 29, 2024.) “Stress is not a diagnosis, disease, or syndrome. It is a nonspecific set of emotions or physical symptoms that may or may not be associated with a disease or syndrome. Whether or not stress contributes to a disease or syndrome depends on the vulnerability of the individual, the intensity, duration, and meaning of the stress; and the nature and availability of modifying resources.” (American College of Occupational and Environmental Medicine (ACOEM) Practice Guidelines, 2nd Edition at p. 1055.) However, stress may cause a physical injury or a psychiatric injury or both.

QME Dr. Fischer provided substantial medical evidence that stress from decedent’s employment contributed to his sudden cardiac arrest and death on November 10, 2023.

Favours Applicant prevailed

This medical opinion met the standard of reasonable medical probability and was relied upon by the WCJ and Board to find compensability.

Defendant’s attempts to impeach applicant’s credibility were rejected due to lack of substantial evidence and impeached defense witness testimony.

Favours Applicant prevailed

Credibility of applicant’s testimony was upheld, supporting the finding of compensability.

From the decision · page 4The only issue presented for adjudication at trial was whether decedent’s death arose out of and in the course of his employment. (Minutes of Hearing and Summary of Evidence (MOH), May 18, 2026, p. 2.) Defendant argued in defense that the QME reports did not constitute substantial medical evidence of compensability, and that applicant lacked credibility. (Ibid.) All other issues were deferred. (Ibid.) As an initial matter, we give great deference to the credibility determinations of the WCJ because the WCJ had the opportunity to observe the demeanor of the witnesses. (Garza v. Workmen’s Comp. Appeals Bd. (1970) 3 Cal.3d 312, 318-319 [35 Cal.Comp.Cases 500, 504-505]; also see Meiner v. Ford Motor Co. (1971) 17 Cal.App.3d 127, 140-141.) 3 Only evidence of considerable substantiality would warrant rejecting a WCJ’s credibility determination. (Garza, supra, 3 Cal.3d at 318-319.) We find no such evidence in the record of this case and concur with the WCJ’s conclusion that defendant cannot rely on speculation to attack applicant’s credibility. (Report, p.

Dr. Fischer opined with reasonable medical probability that stress from decedent’s employment contributed to his sudden cardiac arrest and death, stating there was a greater than 1% medical probability that job stress was an industrial component of death.

Based on comprehensive review of medical records, depositions, and scientific medical knowledge, Dr. Fischer concluded employment stress contributed to decedent’s death.

South Coast Framing, Inc. v. Workers’ Comp. Appeals Board (Clark) (2015) Cal.4th 291

Employment need only be a contributing cause of death for compensability under workers' compensation law.

The Board applied the Clark standard to find that the decedent’s employment stress was a contributing cause of his sudden cardiac arrest and death, supporting compensability.

From the decision · page 5employment need only be a contributing cause of decedent’s death in order for the death to be compensable. (South Coast Framing, Inc., et al. v. Workers’ Comp. Appeals Board (Clark) (2015) Cal.4th 291, 297-299 [2015 Cal. LEXIS 3896]; Wickham v. North American Rockwell Corp. (1970) 8 Cal.App.3d 467, 473 [35 Cal.Comp.Cases 751] citing Madin v. Industrial Acc. Com. (1956) 46 Cal.2d 90, 92-93.) “[I]ndustrial causation itself need not be certain, but only ‘reasonably probably.’” (McAllister v. Workmen’s Comp. Appeals Board (1968) 69 Cal.2d 408, 417 [33 Cal.Comp.Cases 660] (McAllister).) Of course, a WCJ’s decision on compensability must be based on admitted evidence (Hamilton v. Lockheed Corporation (2001) 66 Cal.Comp.Cases 473, 476 (Appeals Bd. en banc)), and must be supported by substantial evidence. (Lab. Code, §§ 5903, 5952(d); Lamb v. Workmen’s Comp. Appeals Bd. (1974) 11 Cal.3d 274 [39 Cal.Comp.Cases 310].) To be considered substantial evidence, a medical opinion does not require absolute certainty but rather, “must be predicated on reasonable medical probability.” (E.L. Yeager Construction v. Workers’ Comp.

Credibility determinations of the WCJ were given great deference; defendant’s attempts to impeach applicant’s credibility were rejected due to lack of substantial evidence and impeached defense witness testimony.

From the decision · page 4The only issue presented for adjudication at trial was whether decedent’s death arose out of and in the course of his employment. (Minutes of Hearing and Summary of Evidence (MOH), May 18, 2026, p. 2.) Defendant argued in defense that the QME reports did not constitute substantial medical evidence of compensability, and that applicant lacked credibility. (Ibid.) All other issues were deferred. (Ibid.) As an initial matter, we give great deference to the credibility determinations of the WCJ because the WCJ had the opportunity to observe the demeanor of the witnesses. (Garza v. Workmen’s Comp. Appeals Bd. (1970) 3 Cal.3d 312, 318-319 [35 Cal.Comp.Cases 500, 504-505]; also see Meiner v. Ford Motor Co. (1971) 17 Cal.App.3d 127, 140-141.) 3 Only evidence of considerable substantiality would warrant rejecting a WCJ’s credibility determination. (Garza, supra, 3 Cal.3d at 318-319.) We find no such evidence in the record of this case and concur with the WCJ’s conclusion that defendant cannot rely on speculation to attack applicant’s credibility. (Report, p.