Movie Extra Gets Lost and Dies – Industrial Causation found

New CAPPS LLC v. WCAB, Daniel Harris (Dec’d), Victoria Harris (Widow), 2016 Cal.Wrk. Comp: Decedent, who was employed as a movie extra by a production company, was found dead in his car on 10/1/12 almost 14 hours after leaving the movie set and approximately one-half mile from the road to the movie production base-camp where he was working.  The coroner estimated decedent’s death at approximately 7:30pm on the previous day, four hours after he left the movie set. Decedent’s wife (Applicant) filed a claim for death benefits.  WCJ found that Applicant met burden of proving that her husband suffered a fatal injury AOE/COE while working for the employer based on the PQME report which concluded that it was medically probable that decedent’s death was caused by an acute cardiac arrhythmia and by decedent’s reaction to being lost in the remote area with a spotty cell phone reception and temperatures of 108 or 109 degrees. WCAB also found that “material deviation” defense did not apply because the deviation was not intentional as decedent got lost.