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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. ADJ17343281
Regular
Apr 14, 2025

HARRIS WELLS vs. METROPOLITAN TRANSIT AUTHORITY

Harris Wells, a revenue collector, sustained injuries to his feet, ankles, and low back while employed by Metropolitan Transit Authority. The WCJ awarded temporary disability and attorney's fees but denied the defendant credit for EDD reimbursements. Defendant petitioned for reconsideration, arguing the WCJ erred in denying the credit. The Appeals Board granted reconsideration, rescinded the First Amended Findings and Award, and returned the matter for further proceedings. This was due to the WCJ's failure to make findings of fact on temporary disability and attorney's fees, and precluding the defendant from pursuing a credit for EDD reimbursements without proper adjudication.

Workers Compensation Appeals BoardPetition for ReconsiderationFindings and AwardTemporary Disability IndemnityEDD Reimbursement CreditRichter v. Frontier CommunicationsPermanent DisabilityMedical Reporting InconsistenciesExpedited TrialLabor Code Section 5909
References
7
Case No. ADJ1626199 (SAC 0323236)
Regular
Aug 03, 2009

Steven Williams vs. Earthlink, Inc., Federal Insurance Company, CHUBB SERVICES CORPORATION

This case concerns a dispute over reimbursement for Employment Development Department (EDD) benefits paid to the applicant, Steven Williams. The Workers' Compensation Appeals Board previously ruled that Earthlink, Inc. was entitled to credit for the full EDD lien amount, reversing an earlier Administrative Law Judge decision that ordered additional payment. The Board affirmed its prior decision, finding no error in allowing credit for the EDD payments. Both parties' requests for sanctions against each other were denied.

WCABReconsiderationFindings and AwardEmployment Development DepartmentEDD LienLabor Code §4903.2Cumulative TraumaTemporary Total DisabilityIndemnityCredit
References
0
Case No. MISSING
Regular Panel Decision

Claim of Jones v. Chevrolet-Tonawanda Division, GMC

This case involves appeals from two decisions by the Workers’ Compensation Board concerning a self-insured employer’s entitlement to credit for holiday wages paid to disabled employees. Claimants Hanks and Jones were injured during employment, resulting in lost time, including holidays. The employer paid them compensation for lost time but also provided full wages for holidays as per collective bargaining agreements, subsequently seeking reimbursement under Workers’ Compensation Law § 25 (4)(a). The Board denied these reimbursement requests, stating that holiday pay was a contractual right and not intended to be in lieu of compensation. The appellate court reversed the Board’s decisions, ruling that denying reimbursement would lead to claimants receiving both full wages and compensation for the holidays, creating an imbalance. Therefore, the employer is entitled to reimbursement, and the matters are remitted to the Workers’ Compensation Board for further proceedings consistent with this decision.

Workers' CompensationHoliday PayReimbursementCollective Bargaining AgreementDisabled EmployeesLost WagesSelf-Insured EmployerAppellate ReviewBoard Decision ReversalStatutory Interpretation
References
2
Case No. ADJ4718149 (GRO 0034104) ADJ708995 (GRO 0034105)
Regular
Jul 03, 2012

ART QUIROS vs. SUPERIOR TANK COMPANY, INC., SEABRIGHT INSURANCE COMPANY

The Workers' Compensation Appeals Board granted reconsideration and rescinded an earlier order awarding reimbursement to the Employment Development Department (EDD). The Board found that EDD's claim for reimbursement was invalid because EDD failed to provide the defendant with proper written notice of the lien claim and its extent, as required by Labor Code section 4904(a). Although EDD argued oral notice was given at hearings, the Board held that statutory law mandates written notification for a lien to be valid. Therefore, EDD's claim for reimbursement was disallowed.

Workers' Compensation Appeals BoardSuperior Tank CompanySeabright Insurance CompanyEmployment Development Departmentlien claimCompromise and Releasewritten noticeLabor Code section 4904(a)actual or constructive noticetemporary disability benefits
References
0
Case No. ADJ1975641 (SRO 0139288)
Regular
Nov 15, 2010

LETEBRHAN BERHE vs. DLK VENTURES INC. dba HANNA HOUSE, RIDLEY NURSING HOME; VIRGINIA, SURETY INSURANCE COMPANY as, administered by FIRSTCOMP OMAHA

Defendant seeks reconsideration of an award finding applicant sustained a work injury and granted benefits, including reimbursement to EDD from applicant's permanent disability award. The defendant contends the WCJ erred by not ordering applicant to reimburse EDD directly. The Appeals Board granted reconsideration, rescinded the decision, and returned the matter to the trial level. This action was taken to allow the WCJ to determine EDD's entitlement to reimbursement directly from the defendant, given the defendant's failure to notify EDD of permanent disability payments after receiving EDD's lien notice.

WORKERS' COMPENSATION APPEALS BOARDDLK VENTURES INC.HANNA HOUSERIDLEY NURSING HOMEVIRGINIA SURETY INSURANCE COMPANYFIRSTCOMP OMAHAADJ1975641SRO 0139288LETEBRHAN BERHEFindings and Award
References
0
Case No. ADJ9282902
Regular
Oct 10, 2017

JUAN CARRILLO vs. ASKEW INDUSTRIAL CORPORATION, TWIN CITY FIRE INSURANCE COMPANY

The Workers' Compensation Appeals Board dismissed the Employment Development Department's (EDD) petition for reconsideration. The EDD sought interest on reimbursement awarded for disability benefits, but the original Findings and Award did not specify the reimbursement amount or rule on interest. The Board found the EDD was not aggrieved by the initial award, as the parties were instructed to adjust the amount themselves. Therefore, the EDD must first seek a final order on the reimbursement amount before pursuing reconsideration.

Workers' Compensation Appeals BoardPetition for ReconsiderationFindings and Awardtemporary disability indemnityreimbursementEmployment Development Department (EDD)lienUnemployment Insurance Code section 2629.1interestadministrative law judge (WCJ)
References
0
Case No. ADJ7917429
Regular
Mar 10, 2014

ROBERTO SALAZAR vs. WTS INTERNATIONAL, INC., TRAVELERS PROPERTY CASUALTY COMPANY OF AMERICA

This case concerns a dispute over defendant's credit for Employment Development Department (EDD) payments against the applicant's permanent disability award. Initially, the WCJ granted the defendant credit for the entire period EDD paid benefits. Upon reconsideration, the Appeals Board clarified that the defendant is only entitled to credit for EDD payments made from January 2, 2012, to May 10, 2012, as these were effectively permanent disability advances. The Board rescinded the original award and amended the findings to reflect this adjusted credit.

Petition for ReconsiderationStipulated AwardPermanent DisabilityTemporary DisabilityCredit for PaymentsEmployment Development DepartmentEDDState Disability InsuranceSDIReimbursement
References
1
Case No. ADJ7176518
Regular
Nov 13, 2013

TRAVIS RIEL vs. STATE OF CALIFORNIA, DEPARTMENT OF FORESTRY, Lawfully Uninsured

This case concerns Travis Riel's workers' compensation claim for a 2007 spinal injury. The Appeals Board dismissed Riel's petition for reconsideration as premature, as it concerned a non-final order regarding EDD reimbursement, and Riel failed to serve EDD. The Board denied the defendant's petition, affirming the finding that Riel sustained new and further permanent disability, and that his claim was not barred by the statute of limitations. The WCJ's conditional order for EDD reimbursement was not a final determination and Riel is not yet liable to reimburse EDD.

New and further disabilityPetition to reopenStatute of limitationsLabor Code section 4656(c)(1)Employment Development Department (EDD)ReimbursementPermanent and stationary dateAggrieved partyFinal orderPetition for reconsideration
References
2
Case No. ADJ8860181
Regular
Jul 16, 2015

GARY GATSON vs. BIMBO BAKERIES USA, INC., ACE AMERICAN INSURANCE COMPANY

This case involves a dispute over the Employment Development Department's (EDD) lien for temporary disability benefits paid to the applicant. The original award found the applicant sustained a cumulative trauma injury and awarded temporary disability benefits, but only allowed partial reimbursement to EDD. Both EDD and the employer sought reconsideration, with EDD arguing for full reimbursement and the employer challenging the EDD lien finding. The Appeals Board granted EDD's petition, denied the employer's, and will allow further proceedings to determine the correct amount of EDD's lien and temporary disability award.

WCABcumulative traumaAchilles tendonpermanent disabilitytemporary disabilityEDD lienreconsiderationsubstantial evidencestandingLabor Code section 4904
References
0
Case No. 2019 NY Slip Op 04295 [172 AD3d 655]
Regular Panel Decision
May 30, 2019

Capital Bus. Credit LLC v. Tailgate Clothing Co., Corp.

The Appellate Division, First Department, affirmed a Supreme Court order regarding a dispute between Capital Business Credit LLC (plaintiff) and Tailgate Clothing Company, Corp. (defendant). Plaintiff purchased accounts receivable from a nonparty related to clothing manufacturing. Defendant paid some invoices but left 12 outstanding. Defendant claimed an equitable recoupment credit for payments made to the Worker Rights Consortium (WRC) for severance pay to Honduran workers, which became due after the manufacturer violated local law by not paying severance. The Court found issues of fact precluding summary judgment on the account stated claim and correctly sustained the equitable recoupment defense, noting it was based on transactions linked to the defendant's licensing and manufacturing agreements. The court also rejected plaintiff's waiver and estoppel arguments.

Equitable recoupmentAccount stated claimSummary judgmentAccounts receivableBreach of contractTimeliness of objectionLicensing agreementManufacturing agreementHonduran labor lawSeverance pay
References
6
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