Eric Pasquotto, Applicant vs. Hayward Lumber, Connecticut Indemnity Insurance Company, and Athens Administrators (Adjusting Agent)

This case holds that an order approving a compromise and release agreement is not a 'prior award of permanent disability' under Labor Code section 4664(b), but evidence from the prior injury may still be relevant for apportionment under section 4663. It also affirms that medical rehabilitation from a prior disability remains a viable concept under section 4663.