JOSE G. LIZARRAGA (DECEASED) vs. WATSONVILLE PRODUCE, REPUBLIC INDEMNITY COMPANY OF AMERICA
This case concerns whether a binding compromise and release agreement was formed before the applicant's death. The Appeals Board denied reconsideration, finding that the agreement was not "duly executed" as required by statute because the defendant had not signed it, and a Medicare set aside provision was still pending. The majority concluded that a complete meeting of the minds on all material aspects was lacking, making the WCJ's prior finding of a binding agreement erroneous.