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. VNO 382502; VNO 382503 VNO 382504; VNO 382505
Regular
May 15, 2008

DOREEN JONES vs. DAVID & BARBARA SALKIN, SPECIALTY RISK SERVICES, ALLSTATE INSURANCE COMPANY

The Workers' Compensation Appeals Board granted reconsideration to amend a previous decision regarding retroactive vocational rehabilitation maintenance allowance (VRMA). The Board affirmed the applicant's entitlement to VRMA but modified the order to allow the defendant credit for VRMA paid during a specific period. The issue of a potential penalty for unreasonable delay was deferred pending further record development.

Vocational Rehabilitation Maintenance AllowanceVRMARehabilitation UnitReconsiderationFindings and OrderWorkers' Compensation Appeals BoardWCJPenaltyLabor Code Section 5814(a)Credit
References
Case No. MON 219697
Regular
Dec 21, 2007

GLORIA CASSADY vs. NATIONAL STAFF NETWORK, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION, CAMBRIDGE INTEGRATED SERVICES, RELIANCE INSURANCE COMPANIES

The WCAB granted reconsideration for CIGA, vacating the award of retroactive VRMA due to the Rehabilitation Unit's primary jurisdiction. The Board denied applicant's and lien claimant's petitions, affirming the WCJ's decision regarding the third-party credit and apportionment of permanent disability. The WCAB also confirmed the attorney's fee at 12% of temporary disability and VRMA, noting an error in the initial permanent disability rating which was corrected.

Workers' Compensation Appeals BoardCalifornia Insurance Guarantee AssociationReliance Insurance CompaniesliquidationRehabilitation Unitvocational rehabilitationVRMAretroactive VRMAthird-party recoverycredit
References
Case No. MON 0288316, MON 314548
Regular
Mar 13, 2008

VICKIE WARD vs. DEPARTMENT OF JUSTICE, STATE COMPENSATION INSURANCE FUND, STATE CONTRACT SERVICES

The Workers' Compensation Appeals Board denied the Department of Justice's petition for reconsideration, affirming the administrative law judge's award of retroactive vocational rehabilitation maintenance allowance (VRMA). The Board found that the defendant failed to provide a timely notice of vocational rehabilitation eligibility after the applicant's physician declared her a qualified injured worker. This failure triggered the applicant's entitlement to VRMA from the date of that medical determination, despite prior notices and deferrals.

Workers' Compensation Appeals BoardVocational Rehabilitation Maintenance AllowanceVRMAQualified Injured WorkerQIWNotice of Potential EligibilityNOPEDeferral NoticeLabor Code Section 4636Labor Code Section 4637
References
Case No. ADJ3845030 (SFO 0486130)
Regular
Jan 13, 2009

RONALD SOUSA vs. UNITED AIRLINES, GALLAGHER BASSETT, INC.

Reconsideration granted; case returned to trial level to determine commencement date of defendant's liability for VRMA and explain grounds for decision.

Workers' Compensation Appeals BoardVocational Rehabilitation Maintenance AllowanceVRMAPermanent and Stationary DateRehabilitation UnitFindings and OrderPetition for ReconsiderationLabor CodeAdministrative Director RuleQualified Injured Worker
References
Case No. ADJ1908213
Regular
Mar 11, 2009

ROBERT WARD vs. LOS ANGELES UNIFIED SCHOOL DISTRICT, PSI AND ADJUSTED BY SEDGWICK CLAIMS MANAGEMENT SERVICES

The Workers' Compensation Appeals Board denied the applicant's petition for reconsideration, upholding the WCJ's decision that applicant was entitled to retroactive vocational rehabilitation maintenance allowance (VRMA) but not at the delay rate. The Board found the delay in VRMA reinstatement was caused by the applicant's pursuit of a settlement rather than the employer's actions. The issue of a Labor Code section 5814 penalty was deferred by the WCJ and therefore not addressed in this order.

Vocational Rehabilitation Maintenance AllowanceVRMA delay rateLabor Code section 5814 penaltyretroactive VRMAPetition for Reconsiderationindustrial injurypermanent disabilityvocational rehabilitation benefitssettlement negotiationsRehabilitation Unit
References
Case No. ADJ4265715
Regular
Jul 14, 2010

ARNIE K. RAGLAND vs. METROPOLITAN PROVISION, ARGONAUT INSURANCE COMPANY

This case involves an applicant seeking retroactive vocational rehabilitation maintenance allowance (VRMA) benefits after the statutory basis for these benefits was repealed. The applicant's entitlement to VRMA from a specific date forward was established by a Rehabilitation Unit Determination that became final before the repeal. The Appeals Board granted reconsideration, rescinded the prior adverse finding, and remanded the case for determination of the specific VRMA amounts due based on that final Determination. Therefore, the applicant's right to VRMA from the date of the final Determination vested before the statute's repeal.

VRMAVocational RehabilitationVested RightLabor Code 139.5RepealRehabilitation UnitDeterminationWorkers' Compensation Appeals BoardIndustrial InjuryPermanent Disability
References
Case No. ADJ1629575 (MON 0296496)
Regular
Oct 06, 2008

SCOTT BICKLEY vs. COUNTY OF LOS ANGELES/SHERIFF'S DEPARTMENT, TRISTAR RISK MANAGEMENT

The Appeals Board granted reconsideration and reversed the WCJ's decision, finding applicant was not entitled to retroactive vocational rehabilitation maintenance allowance (VRMA) at the delay rate. The Board reasoned that no delay in VRMA provision occurred as applicant declined services at the initial meeting, negating the applicability of Labor Code section 4642. Therefore, applicant is not entitled to the claimed VRMA payments from February 7, 2006, to September 5, 2007.

Workers' Compensation Appeals BoardVocational Rehabilitation Maintenance AllowanceVRMADelay RateLabor Code Section 4642Qualified Rehabilitation RepresentativeQRRVocational Rehabilitation ServicesRetroactive PaymentsSettlement
References
Case No. ADJ3730512 (FRE 0210105)
Regular
Aug 28, 2009

Roy Dettling vs. MERCED COMMUNITY COLLEGE, JT2 INTEGRATED SAN RAMON

In *Dettling v. Merced Community College*, the Appeals Board rescinded a prior award of retroactive vocational rehabilitation maintenance allowance (VRMA). The Board found that the repeal of Labor Code § 139.5 on January 1, 2009, terminated all pending and non-final vocational rehabilitation claims. Because the applicant's VRMA award was not final before the repeal, his right to these benefits was extinguished. The case was returned to the trial level for further proceedings not involving VRMA.

Workers' Compensation Appeals BoardReconsiderationVocational RehabilitationLabor Code § 139.5Qualified Injured WorkerVRMAWeiner v. Ralphs CompanyRepealNon-finalVested Rights
References
Case No. ADJ1798478 (LAO 0854694) ADJ2522770 (LAO 0856810)
Regular
May 13, 2009

KAREN BURTON-BARLOW vs. LOS ANGELES COUNTY SUPERIOR COURT, INTERCARE ORANGE

In this workers' compensation case, the Board granted reconsideration of an award of retroactive vocational rehabilitation maintenance allowance (VRMA). The defendant argued VRMA was improperly awarded as the applicant's cumulative trauma injury occurred after the statutory phase-out of such benefits. The Board is returning the case to the trial level due to jurisdictional questions regarding VRMA awards issued after the repeal of Labor Code § 139.5, pending related en banc decisions. The parties are encouraged to attempt informal resolution.

Vocational Rehabilitation Maintenance AllowanceVRMALabor Code Section 139.5repealphase-outcumulative traumaAMEFindings and AwardReconsiderationReport and Recommendation
References
Case No. VNO 0468876
Regular
Jul 19, 2007

PATRICK METOYER vs. CITY OF LOS ANGELES

The Workers' Compensation Appeals Board granted reconsideration, rescinding the lower judge's order that applicant was entitled to vocational rehabilitation maintenance allowance (VRMA) at the "legal rate" without offset for earnings. The Board remanded the case for recalculation of VRMA considering applicant's earnings during the relevant period, noting the "legal rate" was not sufficiently defined and that applicant's employment income necessitated a wage loss calculation. The Board also vacated the penalty and attorney fees awarded due to the dispute over VRMA calculation.

WORKERS' COMPENSATION APPEALS BOARDRECONSIDERATIONVOCATIONAL REHABILITATION MAINTENANCE ALLOWANCEVRMALEGAL RATEWAGE LOSSREHABILITATION UNITFINDINGS AND ORDERLABOR CODE SECTION 5814ATTORNEYS' FEES
References
Showing 1-10 of 82 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