Good Faith Personnel Action Defense Barred Migraine Claim

An employer's use of the good faith personnel action defense in Labor Code 3208.3 barred a technician's claim for migraine headaches, according to California's 4th District Court of Appeal. Case: County of San Bernardino v. WCAB (McCoy), No. E053173, 2/29/12, published.Facts: John McCoy, an automated systems technician for the County of San Bernardino, filed a workers' compensation claim alleging a cumulative trauma injury to his psyche from July 2005 through January 2006. He added a claim of injury for migraine headaches on the first day of trial. McCoy argued that his injurie...