MARC KELLER vs. CITY OF LOS ANGELES
The Workers' Compensation Appeals Board (WCAB) rescinded a prior finding of unreasonable delay in payments by the City of Los Angeles (City). The WCAB found that the City's application of a credit from one case to the front end of an award in another case was not unreasonable, as the stipulation was silent on the deduction method. Additionally, the WCAB determined that the City's deduction for the present value of a commuted attorney's fee in a separate case was a proper calculation of the award, not an unreasonable withholding. Consequently, no penalties or interest were deemed due.