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  January 29, 2007
   Source:  WorkInjury.com
  ----------------------------

We reported earlier this month on yet another case involving one of the exceptions enumerated in Labor Code Section 4660(d) -- SCIF v. WCAB (Echeverria).

That was an unpublished opinion by the First District ruling that a single-sentence treating doctor form letter, which opines that permanent disability was probable, was not enough to trigger the treating report exception of the statute because the ultimate finding of the existence of PD didn't actually come until after January 1, 2005 (despite the attempted wording in the earlier form letter "report").

The Court held that the new PDRS had to be used.

Well, the Court has now certified this case for publication so it may be cited. To read our earlier article on the case, along with a link to the opinion itself, CLICK HERE.

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