CompFox Logo
AboutWorkflowFeaturesPricingCase LawInsights

Updated Daily

Case Law Database

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

Case No. ADJ9346293
Regular
Jul 03, 2018

ANTHONY DENNIS vs. STATE OF CALIFORNIA - DEPARTMENT OF CORRECTIONS INMATE CLAIMS, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board granted reconsideration and overturned a prior decision finding the applicant, an inmate, ineligible for Supplemental Job Displacement Benefits (SJDB). The Board determined that while the applicant's appeal of the Administrative Director's presumed denial was untimely under specific regulations, the Board retains exclusive jurisdiction to adjudicate SJDB eligibility. They found the employer's offer of modified work was not bona fide as the applicant was released from prison, thus the statutory exception to SJDB did not apply. Therefore, the applicant is entitled to SJDB.

Workers' Compensation Appeals BoardSupplemental Job Displacement BenefitSJDBAdministrative DirectorRule 10133.54untimely appealdue processexclusive jurisdictioninmate laborervocational rehabilitation
References
5
Case No. ADJ 7552376
Regular
Apr 04, 2016

HECTOR REYES BARRERA vs. RCO REFORESTING, STATE COMPENSATION INSURANCE FUND

Applicant Hector Reyes Barrera sought reconsideration of a WCJ's decision that he settled his right to a Supplemental Job Displacement Benefits (SJDB) voucher in a Compromise and Release (C&R) agreement. Barrera argued he did not understand he was waiving this benefit and did not initial the relevant section. However, the C&R clearly stated the settlement amount included monies for the SJDB voucher, and the Order Approving C&R explicitly included SJDB in the release. Therefore, the Workers' Compensation Appeals Board denied reconsideration, upholding the finding that Barrera settled his entitlement to the SJDB voucher.

Supplemental Job Displacement BenefitsSJDB voucherCompromise and ReleaseC&RPetition for ReconsiderationWorkers' Compensation Appeals BoardWCJwaivervocational rehabilitationentitlement
References
0
Case No. ADJ9721385
Regular
Jun 07, 2016

JUAN PABLO BELTRAN vs. STRUCTURAL STEEL FABRICATORS, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board granted reconsideration, overturning a WCJ's order that disallowed settlement of a Supplemental Job Displacement Benefit (SJDB) voucher. The Board held that parties can settle an SJDB voucher claim in a Compromise and Release Agreement if a good faith dispute exists that could defeat the applicant's entitlement to all workers' compensation benefits. In this case, the applicant's failure to report the injury before termination constituted such a good faith dispute, allowing the settlement of the SJDB voucher. The Board therefore approved the parties' original Compromise and Release Agreement, including the settlement of the SJDB voucher.

Supplemental Job Displacement BenefitCompromise and ReleaseGood Faith DisputeSB863Vocational RehabilitationLabor Code Section 4658.7Petition for ReconsiderationWorkers' Compensation Appeals BoardAffirmative DefenseAOE/COE
References
2
Case No. ADJ9346293
Significant
Jan 13, 2020

ANTHONY DENNIS vs. STATE OF CALIFORNIA – DEPARTMENT OF CORRECTIONS AND REHABILITATION INMATE CLAIMS, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board issued a Notice of Intention to find Administrative Director Rule 10133.54 invalid, asserting it oversteps the Administrative Director's authority and infringes upon the WCAB's exclusive jurisdiction to adjudicate disputes over supplemental job displacement benefits (SJDB). The Board also intends to hold that an employer must make a bona fide offer of work to avoid liability for an SJDB voucher.

Supplemental Job Displacement BenefitSJDB voucherAdministrative DirectorAD Rule 10133.54Workers' Compensation Appeals BoardWCABexclusive jurisdictionstatutory authoritybona fide offerregular work
References
33
Case No. ADJ9346293
En Banc
Jan 13, 2020

ANTHONY DENNIS vs. STATE OF CALIFORNIA – DEPARTMENT OF CORRECTIONS AND REHABILITATION INMATE CLAIMS, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board (WCAB) issued a Notice of Intention to hold that Administrative Director (AD) Rule 10133.54 is invalid. The WCAB reasoned that the rule exceeds the AD's statutory authority and improperly restricts the WCAB's exclusive jurisdiction to adjudicate disputes over supplemental job displacement benefits (SJDB). The board also intends to affirm its prior decision that an employer must make a bona fide offer of work to an injured employee to be exempt from providing an SJDB voucher.

AD Rule 10133.54Supplemental Job Displacement BenefitBona Fide OfferExclusive JurisdictionAdministrative DirectorWorkers' Compensation Appeals BoardInmate LaborerStatutory AuthorityEn Banc DecisionReconsideration
References
31
Case No. ADJ10579672
Regular
Jan 03, 2019

EVELYN MENDOZA vs. VINTAGE SENIOR LIVING, SAFETY NATIONAL CASUALTY CORPORATION

The Appeals Board denied the applicant's petition for reconsideration, affirming the WCJ's nunc pro tunc order. This order amended the original Compromise and Release to include a finding that a good faith dispute existed regarding the injury AOE/COE, which was necessary to extinguish liability for a Supplemental Job Displacement (SJDB) voucher. The Board found that the WCJ intended to settle the SJDB voucher claim at the time of the original order but failed to explicitly record this finding. Therefore, the nunc pro tunc order corrected a clerical omission to reflect the court's prior decision, rather than altering the substance of the original judgment.

Workers' Compensation Appeals BoardEvelyn MendozaVintage Senior LivingSafety National Casualty CorporationAthens AdministratorsADJ10579672Opinion and Decision After ReconsiderationFindings of Fact and OrdersCompromise and ReleaseNunc Pro Tunc
References
3
Case No. ADJ10588071, ADJ9823909
Regular
Feb 02, 2023

LILLIAN LONA vs. THE DISNEYLAND RESORT, DISNEY ANAHEIM

Here's a summary of the case in four sentences for a lawyer: Applicant Lillian Lona sought an extension for her Supplemental Job Displacement Benefit (SJDB) voucher, which expired March 18, 2021, due to COVID-19 restrictions. She argued the pandemic created a legal impossibility preventing her from utilizing the voucher for computer training. The Workers' Compensation Appeals Board (WCAB) found that the unprecedented pandemic circumstances indeed created a legal impossibility excusing timely compliance with the statutory two-year voucher limit. Consequently, the WCAB granted Lona an additional 15 months from the Opinion's service date to use her SJDB voucher.

Supplemental Job Displacement BenefitSJDB voucherLabor Code section 4658.7(f)Executive Order N-33-20COVID-19 pandemicstay-at-home orderlegal impossibilitytollingvocational retrainingcomputer training
References
10
Case No. ADJ4152685
Regular
Oct 23, 2013

FLORIDA SILVA vs. RIOS FARM LABOR SERVICES, LIBERTY MUTUAL INSURANCE COMPANY

The Workers' Compensation Appeals Board denied Florida Silva's Petition for Reconsideration, upholding the denial of her claim for attorney's fees and penalties. The denial stemmed from the applicant's failure to formally petition for penalties or raise attorney's fees and costs as issues during the Mandatory Settlement Conference or trial. The board found that the SJDB voucher issue became moot when it was eventually provided, and without a formal petition for penalties, there was no basis for an award of fees.

Workers' Compensation Appeals BoardPetition for ReconsiderationSupplemental Displacement Job BenefitSJDB voucherunreasonable delayLiberty Mutual Insurance CompanyRios Farm Labor ServicesLabor Code section 5814.5attorney's feespenalties
References
0
Case No. ADJ3765961 (LAO 0871712)
Regular
Jun 07, 2010

JESSE FRANCIS vs. RUSSELL CONSTRUCTION SERVICES, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board denied defendant's petition for reconsideration regarding attorney's fees awarded based on a Supplemental Job Displacement Benefit (SJDB). The Board found the defendant waived any objection to the fees by stipulating to them and that no good cause existed to set aside the stipulation. The Board is also initiating sanctions against defendant's counsel for filing a frivolous petition without merit. The matter is removed to consider sanctions against the defendant's counsel, including a potential additional attorney's fee for the applicant's attorney.

Supplemental Job Displacement BenefitSJDBAttorney's FeesStipulationsPetition for ReconsiderationSanctionsLabor Code § 5813Good CauseFrivolous PetitionIndustrial Injury
References
4
Case No. ADJ10887310
Regular
Jan 30, 2023

OSCAR MARTINEZ vs. SECURITA AMERICA, INC., GALLAGHER BASSETT, EVEREST NATIONAL INSURANCE

The applicant, Oscar Martinez, was injured on May 3, 2017, resulting in a 3% permanent disability. He returned to his regular job duties with his employer, Securita America, Inc., but was laid off approximately five months later due to his employer's contract ending. While Martinez subsequently worked for a new employer at the same location and performing similar duties, the Board found that this did not satisfy the requirement of returning to the "same job for the same employer" for at least 12 months. Therefore, the Appeals Board amended the prior finding, ruling that Martinez is entitled to a Supplemental Job Displacement Benefit (SJDB) voucher.

Supplemental Job Displacement BenefitSJDB voucherpermanent partial disabilityemployer's dutyregular work offermodified work offeralternative work offer12-month durationRule 10133.31(c)substantial evidence
References
3
Showing 1-10 of 11 results

Ready to streamline your practice?

Apply these legal strategies instantly. CompFox helps you find decisions, analyze reports, and draft pleadings in minutes.

CompFox Logo

The AI standard for workers' compensation professionals. Faster research, deeper analysis, better outcomes.

Product

  • Platform
  • Workflow
  • Features
  • Pricing

Solutions

  • Defense Firms
  • Applicants' Attorneys
  • Insurance carriers
  • Medical Providers

Company

  • About
  • Insights
  • Case Law

Legal

  • Privacy
  • Terms
  • Trust
  • Cookies
  • Subscription

© 2026 CompFox Inc. All rights reserved.

Systems Operational