JEANNE HENDERSON vs. STATE COMPENSATION INSURANCE FUND
Applicant sought reconsideration of a finding that her penalty petition was settled by a Compromise and Release (C&R) agreement. She argued the C&R only addressed specific penalties, excluding her claim for failure to advance permanent disability. The majority ruled that Labor Code section 5814(c) presumes all accrued penalty claims are resolved by a C&R unless expressly excluded, and the language here did not meet that standard. Consequently, the applicant's petition for reconsideration was denied.