MICHAEL BONNER vs. CITY OF LOS ANGELES; permissibly self-insured, administered by TRISTAR RISK MANAGEMENT

This case involves a firefighter, Michael Bonner, seeking workers' compensation benefits. The defendant, City of Los Angeles, sought reconsideration of a prior award granting temporary disability (TD) benefits and a penalty for unreasonable delay. The Appeals Board denied the reconsideration, holding that Labor Code section 4850 salary continuation benefits for firefighters are distinct from temporary disability and do not count against the two-year TD limit under Labor Code section 4656(c)(1). The Board affirmed the penalty, finding the City's attempt to conflate these benefits to limit TD payments unreasonable.