Case No. GRO 0028123, GRO 0028394En BancFeb 27, 2006
ERIC PASQUOTTO vs. HAYWARD LUMBER, CONNECTICUT INDEMNITY INSURANCE COMPANY, ATHENS ADMINISTRATORS
The Appeals Board held that a prior injury settlement via a compromise and release agreement does not constitute a 'prior award of permanent disability' under Labor Code section 4664(b) for apportionment purposes. However, evidence from the prior injury may still be relevant to determine apportionment based on causation under section 4663.
SB 899apportionmentcompromise and releaseprior awardpermanent disabilityLabor Code sections 46634664en banc decisionmedical rehabilitationother factors
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