Workers’ Compensation · Primary-source case analysis

Almaraz/Guzman II: The AMA Guides Rating May Be Rebutted Within the Guides

By Aneeta Mishra and Timothy Chan

Published April 23, 2026

Almaraz/Guzman II defines both the flexibility and the limits of rebutting a scheduled whole-person-impairment rating under California’s 2005 permanent disability system.

Two cases challenged strict application of the Guides

The injured workers argued that ratings obtained by a literal application of the AMA Guides did not fairly describe their impairments. The consolidated matters required the Board to decide whether the Guides component of the schedule was conclusive.

The scheduled rating is rebuttable

The Board concluded that the statutory schedule creates a rebuttable prima facie rating rather than an irrebuttable result. A party may show that a different impairment assessment more accurately reflects the injured worker’s condition.

The alternative must stay within the Guides

A physician may use clinical judgment and analogize to other chapters, tables, or methods in the Guides, but may not abandon the Guides for an unrestricted opinion about disability. The report must explain the facts and reasoning supporting the chosen method.

Disposition

The Board rescinded the challenged decisions and remanded both matters for further development. It did not announce the final impairment percentage for either worker.

Key takeaways

• Begin with the scheduled AMA Guides rating.
• Identify the specific inadequacy claimed in the literal rating.
• Require the physician to explain any Guides-based analogy.
• Separate impairment analysis from ultimate disability adjustment.