FELIX CABRERA vs. OAA INVESTMENTS, INC.; CALIFORNIA RESTAURANT MUTUAL BENEFIT CORP.
Defendant California Restaurant Mutual Benefit Corporation (CRMBC) sought reconsideration of a February 19, 2021 Findings and Order (F&O) which found CRMBC liable for coverage of applicant Felix Cabrera's injury, ruling that CRMBC's policy cancellation was premature. CRMBC contended it had no coverage obligations as the applicant was employed by OAA Investments, Inc., not insured by CRMBC, and argued against the applicability of Insurance Code section 676.8. The Appeals Board affirmed the WCA's F&O, treating the petition as one for reconsideration, and found that under Insurance Code section 676.8 and equitable principles, CRMBC was liable for coverage. The Board reasoned that due to a material change in ownership, CRMBC's cancellation notice required 30 days' notice, making January 27, 2018, the earliest effective cancellation date, which was after the November 22, 2017 injury date.