CHARLES COWART vs. JACK IN THE BOX, INC.
The Workers' Compensation Appeals Board granted reconsideration, rescinding the prior award of penalties for unreasonable delay in funding an annuity. The Board found that applicant's own delay in providing necessary information was the primary cause of the annuity funding delay, thus not warranting a penalty. However, the Board affirmed a $10,000 penalty for the employer's unreasonable delay in paying applicant's attorney's fees, to be paid to the applicant, not the attorney. Attorney's fees for enforcing the compromise and release were deferred for trial level resolution.