TERRI HARRISON vs. CITY OF TORRANCE
The Workers' Compensation Appeals Board granted the defendant's petition for reconsideration, overturning a prior ruling that presumed the applicant's injury compensable due to a late denial. The Board found that the defendant's denial letter, mailed on December 26, 2018, was timely because the 90-day presumption period expired on December 25, 2018, a court holiday, making the next business day the deadline. The employer's inability to definitively prove the claim form's receipt date led the Board to infer a receipt date of September 26, 2018, thus making the December 26 denial compliant with Labor Code section 5402. Consequently, the applicant's injury is not presumed compensable.