Workers’ Compensation · Primary-source case analysis

Rolda: The Required Analysis for a Good-Faith Personnel-Action Defense

By Aneeta Mishra and Timothy Chan

Published April 14, 2026

Rolda separates medical causation from the legal character of workplace events. That separation matters whenever an employer invokes Labor Code section 3208.3(h).

The claimed psychiatric injury

Rick Rolda alleged psychiatric injury arising from events involving sales territories, supervision, leave, and his eventual separation from work. The workers’ compensation judge found industrial injury and concluded that the claim was not barred by the good-faith personnel-action defense. The employer sought reconsideration.

The sequence the WCAB required

The Board required the judge first to identify actual events of employment and then determine, through competent medical evidence, whether those events supplied the necessary industrial causation. The judge must separately decide which events were personnel actions and whether those actions were lawful, nondiscriminatory, and taken in good faith.

Medical evidence returns at the final step

If qualifying personnel actions are established, medical evidence must address whether those actions were a substantial cause of the psychiatric injury. The legal decision about whether conduct is a good-faith personnel action belongs to the adjudicator; the medical decision about causation belongs to qualified medical evidence.

Disposition and limits

Because the original decision did not follow that multilevel analysis, the WCAB rescinded it and returned the matter for further proceedings. Rolda supplies the analytical framework; it did not hold that every supervisory decision is protected or that the defense succeeded on the incomplete record.

Key takeaways

• Identify each actual employment event rather than treating the history as one undifferentiated stressor.
• The judge decides whether an event was a lawful, nondiscriminatory, good-faith personnel action.
• Medical evidence must allocate causation after the legal characterization of events.
• Failure to perform the steps in order can require further proceedings.