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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
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
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
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
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
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
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
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
Case No. ADJ11298015
Regular
May 27, 2025

Elideth Balderrama Ramirez vs. Hotcakes No 6 Inc IHOP 817, Preferred Employers San Diego

Elideth Balderrama Ramirez sought reconsideration of a WCJ's finding that she was precluded from a second Return-to-Work Supplement Program (RTWSP) benefit, despite receiving a second Supplemental Job Displacement Benefit (SJDB) voucher. The applicant contended that her second voucher was 'subsequent' to her first RTWSP payment, fulfilling an exception in Rule 17302(b). The Appeals Board clarified that the exception refers to the date of injury being subsequent, not the voucher issuance date. As the record lacked a finding on the cumulative trauma date of injury, the Board rescinded the previous order and returned the case to the trial level for this determination.

Return-to-Work Supplement ProgramSupplemental Job Displacement BenefitSJDB vouchercumulative trauma injuryspecific injurydate of injuryLabor Code section 139.48Rule 17302Rule 17309Administrative Procedures Act
References
Case No. ADJ13342468
Regular
May 23, 2025

AMELIA MINA vs. NMA INSPECTIONS, DEPARTMENT OF INDUSTRIAL RELATIONS

Applicant Amelia Mina sought reconsideration of an October 3, 2022 Findings and Order, which denied her a second Return-to-Work Supplement Program (RTWSP) benefit under Rule 17302(b). She argued the rule was inconsistent with its authorizing statute, violated equal protection, and constituted invalid special legislation. The Workers' Compensation Appeals Board (WCAB) affirmed the prior decision, finding the applicant's second injury occurred before receipt of the first RTWSP payment, making her ineligible under Rule 17302(b). The Board also determined that the jurisdiction to invalidate Rule 17302(b) lies with the Superior Court under the Administrative Procedures Act, not the Appeals Board.

Workers' Compensation Appeals BoardReturn-to-Work Supplement ProgramRTWSPSupplemental Job Displacement BenefitSJDBRule 17302(b)Labor Code section 139.48Findings and OrderPetition for ReconsiderationCompromise and Release
References
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