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

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. 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. 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. 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. ADJ1039908 (RDG 0121430)
Regular
Nov 07, 2008

AYON vs. CLIFF'S AUTO CENTER, Uninsured, UNINSURED EMPLOYERS BENEFITS TRUST FUND

The Workers' Compensation Appeals Board denied the defendant's petition for reconsideration, upholding the finding that the applicant is entitled to a Job Displacement Voucher. The applicant sustained an industrial injury causing permanent disability and did not return to work for the defendant within 60 days of temporary disability termination. Therefore, the applicant is eligible for a nontransferable voucher of up to $6,000 for educational retraining or skill enhancement, as defined by Labor Code § 4658.5.

Job Displacement VoucherUninsured Employers Benefits Trust FundStipulated AwardPermanent DisabilitySupplemental Job Displacement BenefitLabor Code § 4658.5Nontransferable VoucherEducation-Related RetrainingSkill EnhancementVocational Return to Work Counselor
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. ADJ7850702
Regular
May 04, 2012

MARTA BLACHOWICZ vs. SKYWEST AIRLINES, SEDGWICK CLAIMS MANAGEMENT SERVICES

In this workers' compensation case, the defendant, Skywest Airlines, sought reconsideration of a February 21, 2012 decision. They claimed a mutual mistake in the mathematical calculation of permanent disability and asserted the stipulation for a job displacement voucher did not reflect the parties' true agreement. The applicant countered that the stipulation was a good-faith negotiated settlement. The Administrative Law Judge recommended denying reconsideration, finding the defendant failed to demonstrate mutual mistake. Ultimately, the Petition for Reconsideration was dismissed as withdrawn by the petitioner.

Workers Compensation Appeals BoardPetition for ReconsiderationDismissalSkywest AirlinesSedgwick Claims Management ServicesSan Luis ObispoPetition to Set AsideStipulated AwardMutual MistakeMathematical Error
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. ADJ9559658, ADJ9841710
Regular
Jul 21, 2017

SANDRA MORALES SESENA vs. RESIDENCE INN BY MARRIOTT, LLC

The Workers' Compensation Appeals Board granted reconsideration and amended a prior decision, finding the applicant entitled to a second supplemental job displacement voucher. This is because the applicant sustained two distinct industrial injuries causing permanent partial disability, and the plain language of Labor Code section 4658.7 mandates a voucher for each qualifying injury. The Board rejected the employer's argument that injuries occurring concurrently or having the same stationary date precluded separate vouchers. The applicant is entitled to a separate voucher for each of her injuries to her lumbar spine and hypertension.

Supplemental job displacement voucherLabor Code section 4658.7Petition for ReconsiderationJoint Findings of FactStipulated Awardindustrial injurypermanent partial disabilityseparate vouchersplain meaninglegislative intent
References
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