ROSE SCARBERRY vs. WILLITS HOSPITAL, LIBERTY MUTUAL INSURANCE COMPANY
The Workers' Compensation Appeals Board (WCAB) granted reconsideration of a decision that issued separate permanent disability awards for two industrial injuries, relying on the then-current *Benson* ruling. The WCAB deferred the issues of permanent disability and attorney's fees pending a Court of Appeal decision on *Benson*, which addressed whether successive injuries becoming permanent and stationary simultaneously should be combined or rated separately. The WCAB ordered the defendant to issue advances for permanent disability indemnity based on the original award amounts while withholding a portion pending the final resolution.