California WCABLaw firm

Brown & Delzell

Brown & Delzell is named in 19 released California WCAB decisions from 2021–2026. The disputes run to AOE/COE (6), Temporary disability (5) and Permanent disability rating (3). They were heard most often at San Francisco, then Santa Rosa. The firm it meets most often is Lenahan, Slater, Pearse & Majernik (3).

Decisions: 19
Years: 2021–2026
Issues disputed: 9
District offices: 7

Applicant sideRead off how the firm is printed in the service list of its own decisions — 13 of 17 agree. It is our reading of the record, not the firm’s description of itself.

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.

21 decisions across the groups shown

Who they face

5 more firms appear in the same decisions and are not listed: we could not read which side they were on.

Carriers and administrators

Where they appear

San Francisco 11
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.

12 for the applicant
5 for the defense
2 returned for more record

Counted over 17 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.

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 →
ADJ16975645 · 2024-12-16 · Santa Rosa District OfficeTemporary disabilityapplicant prevailed
Determinative passage · p.2Applicant sustained injury in the form of presumptively compensable cancer. She lost time from work as a result of that injury. Specifically, she was totally disabled for the period October 31, 2022 through September 11, 2023. For this period, she received her full salary replacement pursuant to Labor Code § 4850. She was then returned to work on a part time basis, working 3 days a week and receiving 4850 benefits so that she received her full salary replacement: part from salary and part in 4850 benefits. Defendant ended this on October 27, 2023, at which point applicant had received 52 weeks of 4850 benefits - after which she received partial temporary disability benefits.
The Appeals Board found that section 4850 benefits are payable on a daily basis for up to one year (365 days), not limited to 52 weeks, and that the employer cannot credit salary earned during part-time work against the 4850 benefits entitlement.
Official decision · page 2 →
ADJ18001417 · 2024-10-14 · San Francisco District OfficeJurisdiction / venueremanded
Determinative passage · p.6Here, the WCA issued the Report dated April 25, 2023, however, the record does not include the transcript of proceedings, or the submitted evidence. Moreover, the record does not contain any identification of the stipulations, exhibits, and issues at trial.
The record was incomplete, lacking transcripts, evidence, and identification of stipulations, exhibits, and issues at trial, preventing meaningful review.
Official decision · page 6 →
ADJ14244361 · 2024-09-16 · Sacramento District OfficeQME/AME processmixed
Determinative passage · p.1Applicant seeks reconsideration of the July 3, 2024 Findings of Fact, Award, and Order (F&O), wherein the workers' compensation administrative law judge (WCJ) found that applicant, while employed as a firefighter during the period ending August 5, 2019, sustained industrial injury to her psyche. The WCJ found, in relevant part, that the reporting of Qualified Medical Evaluator (QME) Joseph R. Nevotti, Ph.D., did not constitute substantial medical evidence and that the deficiencies in the QME reporting could not be rehabilitated. Accordingly, the WCJ ordered Dr. Nevotti stricken as the QME and ordered the parties to consider the use of an Agreed Medical Evaluator or to obtain a new panel of QMEs.
The WCJ found the QME's reporting was not substantial evidence and that the QME could not be rehabilitated due to unprofessional conduct and failure to apply correct apportionment law; the WCAB granted reconsideration and ordered a replacement panel of QMEs in psychology to resolve disputed issues.
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
BROWN & DELZELL, LLP
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

12 for the applicant

5 for the defense

2 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.

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 →

ADJ16975645 · 2024-12-16 · Santa Rosa District OfficeTemporary disabilityapplicant prevailed

Determinative passage · p.2Applicant sustained injury in the form of presumptively compensable cancer. She lost time from work as a result of that injury. Specifically, she was totally disabled for the period October 31, 2022 through September 11, 2023. For this period, she received her full salary replacement pursuant to Labor Code § 4850. She was then returned to work on a part time basis, working 3 days a week and receiving 4850 benefits so that she received her full salary replacement: part from salary and part in 4850 benefits. Defendant ended this on October 27, 2023, at which point applicant had received 52 weeks of 4850 benefits - after which she received partial temporary disability benefits.

The Appeals Board found that section 4850 benefits are payable on a daily basis for up to one year (365 days), not limited to 52 weeks, and that the employer cannot credit salary earned during part-time work against the 4850 benefits entitlement.

Official decision · page 2 →

ADJ18001417 · 2024-10-14 · San Francisco District OfficeJurisdiction / venueremanded

Determinative passage · p.6Here, the WCA issued the Report dated April 25, 2023, however, the record does not include the transcript of proceedings, or the submitted evidence. Moreover, the record does not contain any identification of the stipulations, exhibits, and issues at trial.

The record was incomplete, lacking transcripts, evidence, and identification of stipulations, exhibits, and issues at trial, preventing meaningful review.

Official decision · page 6 →

ADJ14244361 · 2024-09-16 · Sacramento District OfficeQME/AME processmixed

Determinative passage · p.1Applicant seeks reconsideration of the July 3, 2024 Findings of Fact, Award, and Order (F&O), wherein the workers' compensation administrative law judge (WCJ) found that applicant, while employed as a firefighter during the period ending August 5, 2019, sustained industrial injury to her psyche. The WCJ found, in relevant part, that the reporting of Qualified Medical Evaluator (QME) Joseph R. Nevotti, Ph.D., did not constitute substantial medical evidence and that the deficiencies in the QME reporting could not be rehabilitated. Accordingly, the WCJ ordered Dr. Nevotti stricken as the QME and ordered the parties to consider the use of an Agreed Medical Evaluator or to obtain a new panel of QMEs.

The WCJ found the QME's reporting was not substantial evidence and that the QME could not be rehabilitated due to unprofessional conduct and failure to apply correct apportionment law; the WCAB granted reconsideration and ordered a replacement panel of QMEs in psychology to resolve disputed issues.

Official decision · page 1 →