California Court of Appeal

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County of San Bernardino v. Workers' Compensation Appeals Board, E053173

On petition for review of an order of the Workers' Compensation Appeals Board finding that an employee was entitled to temporary disability and medical treatment as a result of personnel actions that aggravated preexisting migraines, the order is annulled, where: 1) the good-faith personnel action defense applied; 2) such defense precludes recovery for psychiatric injuries with resulting physiological manifestations solely caused by stress from such actions; and 3) there was no evidence that the employee suffered on-the-job stress apart from that caused by good-faith personnel actions.

Appellate Information

  • Decided 02/29/2012
  • Published 02/29/2012


  • McKinster


  • California Court of Appeal


  • For Appellant:
  • Eric K. Yee, Holstein, Taylor and Unitt