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Case Law Database

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

Case No. ADJ4312477 (GRO 0033744) ADJ2550699 (GRO 0033745) ADJ1243304 (GRO 0033746) ADJ541032 (GRO 0033747) ADJ595387 (GRO 0033748) ADJ1104781 (GRO 0033749)
Regular
Feb 10, 2009

CATHERINE PORTUGAL vs. MIKASA, INC.; GALLAGHER BASSETT SERVICES, INC.

The Appeals Board granted reconsideration and affirmed a WCJ's decision finding the defendant liable for a Labor Code section 5814 penalty due to unreasonable delay in providing a Supplemental Job Displacement Voucher. The Board clarified that the voucher constitutes "compensation" under section 5814 and the penalty should be 25% of the amount ultimately paid from the voucher. The Board also corrected a clerical error regarding the voucher's maximum value to $8,000.

Supplemental Job Displacement VoucherLabor Code section 5814Petition for ReconsiderationWorkers' Compensation Appeals BoardAdministrative Law JudgePenalty AssessmentPermanent DisabilityRehabilitationAttorney's FeeLabor Code section 4658.5
References
0
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
5
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. 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. SFO 483527
Regular
Aug 07, 2007

CARLOS CORTEZ vs. APRIA HEALTHCARE, INSURANCE COMPANY OF THE STATE OF PENNSYLVANIA

The Workers' Compensation Appeals Board granted reconsideration and affirmed a finding of unreasonable delay in providing a supplemental job displacement voucher. The Board upheld the $25\%$ increase to the voucher's value and attorney's fees under Labor Code sections $5814$ and $5814.5$, respectively. However, the calculation of both the increased voucher amount and attorney fees was deferred pending further proceedings to determine their exact values.

Supplemental Job Displacement VoucherCompromise and ReleaseLabor Code section 5814Unreasonable DelayPermanent DisabilityReconsiderationWorkers' Compensation Appeals BoardAdministrative Law JudgeAttorneys' FeeLabor Code section 4658.5
References
1
Case No. ADJ8406355
Regular
Sep 06, 2016

JORGE GARCIA vs. SARA LEE CORPORATION, ACE AMERICAN INSURANCE COMPANY c/o ESIS

The Workers' Compensation Appeals Board (WCAB) granted reconsideration of a judge's award finding Sara Lee Corporation liable for a penalty based on the full $8,000 supplemental job displacement voucher, plus penalties for medication delays and attorney fees. The WCAB agreed that the penalty for the delayed voucher should be limited to 25% of the *actual amount used* by the applicant, not the full voucher amount. The WCAB otherwise affirmed the judge's findings on medication delays and attorney fees, adopting the judge's report.

Supplemental Job Displacement VoucherIndependent Medical ReviewLabor Code section 5814PenaltyReconsiderationFindings and AwardWCJAppeals BoardAttorney's feesActual time spent
References
2
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. 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
7
Case No. OXN 137267
Regular
Aug 14, 2007

MARK STONEBRAKER vs. MASTER COOLING CORPORATION, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board granted reconsideration, affirming that the defendant unreasonably delayed providing a job displacement voucher, entitling the applicant to a penalty. While the Board upheld the award of attorney's fees for enforcing the payment, they modified the penalty calculation. The 25% penalty will now be calculated against the actual amount of the voucher used by the applicant, not its potential maximum value.

Supplemental Job Displacement BenefitJob Displacement VoucherUnreasonable DelayPenaltyAttorney's FeesLabor Code Section 5814Labor Code Section 5814.5Compromise and ReleaseVocational RehabilitationWCJ
References
5
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
0
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