ARTURO LEDESMA vs. BARRETT BUSINESS SERVICES, INC.
The Appeals Board denied defendant's petition for reconsideration of an order finding applicant temporarily totally disabled. The Board affirmed that the Employment Development Department (EDD) is entitled to recover its lien for disability benefits paid during the period of temporary total disability. Temporary disability is not subject to apportionment, though liability for such benefits between carriers on successive injuries can be addressed through contribution proceedings. The Board found substantial evidence supported the temporary disability finding, including EDD records and QME Sofia's reports noting applicant was off work.