JOSE G. LIZARRAGA (DECEASED) vs. WATSONVILLE PRODUCE, REPUBLIC INDEMNITY COMPANY OF AMERICA
The Workers' Compensation Appeals Board reversed a prior decision, holding that a compromise and release agreement was not binding at the time of the applicant's death because it was not "duly executed" as required by statute. Crucially, the defendant had not signed the agreement, and a material provision for a Medicare set-aside allocation was still pending approval. The Board found that the applicant's death occurred before all necessary steps for a validly executed agreement were completed, thus the agreement was not finalized.