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However, in no event shall the disability payment allowed be less than the disability payment computed according to subdivision (b).l1(a)l2Column 2Number of weeks forl2which two-thirds of averagel2weekly earnings allowed forColumn 1Range of percentagel2each 1 percent of permanentof permanent disabilityl2disability within percentageincurred:l2range:Under 10310-19.75420-29.75530-49.75650-69.75770-99.758The number of weeks for which payments shall be allowed set forth in column 2 above based upon the percentage of permanent disability set forth in column 1 above shall be cumulative, and the number of benefit weeks shall increase with the severity of the disability. State inmates are statutorily included in the definition of employee while county inmates are subjected to a compulsory test to determine their employee status. (626) 463-6182 The workers compensation system is premised on a trade-off between employees and employers. We further recognize that sometimes policies and procedures do not translate into practice. Appeals Bd. I certify that I affixed the official seal of the Workers' Compensation Appeals Board to this original decision on this date. You should contact the County Quality Assurance Evaluator, often called a County Monitor, which is headquartered at the workers compensation third party administrator or contact the County Contract Administrator at (213) 738-2154. WORKERS COMPENSATION APPEALS BOARD - 37 Photos - Public Services & Government - 320 W 4th St, Los Angeles, CA - Phone Number - Yelp Workers Compensation Appeals Board 2 reviews Unclaimed Public Services & Government Central Community Police Station Pico Union Branch Library Los Angeles Police Department, Rampart Division Social Security )Here, however, we need not reach the correctness of this point as even under Lorenz Bauer the penalty would not apply to the future medical care as permanent disability payments are a direct monetary payment to the injured worker., 3. No other type of workers' compensation benefits owed to Crowe was delayed by County. 76 and Ramsey v. Workmen's Comp. Please try again. If voluntary and timely payments were not so exempt the employer has no incentive to correct his error. In each of these cases, the WCAB starts its analysis with the definition of employee found in Labor Code, section 3351, as every person in the service of an employer under any appointment or contract of hire or apprenticeship, express or implied, oral or written, whether lawfully or unlawfully employed and includes [a]ll persons incarcerated in a state penal or correctional institution while engaged in assigned work or employment . App. 517, 555 P.2d 303; Vogh v. Workmen's Comp. Disclaimer 3, 65 Cal.Rptr. DIVISION: The Workers' Compensation Division is responsible for defending the City of Los Angeles in industrial injury claims litigated before the Workers' Compensation Appeals Board. (See, . There are six basic types of workers compensation benefits available, depending on the nature, date, and severity of the workers injury: Injured workers are entitled to receive all medical care reasonably required to cure or relieve the effects of the injury/illness, with no deductible or co-payments by the injured worker. Do I Need an Attorney to Handle My Accident Case? 1161 In December 2022, the Workers Compensation Appeals Board (WCAB) issued four panel decisions that defined the parameters for analysis of the employment status of inmate workers for the purposes of determining whether these inmate workers are entitled to the protections of workers compensation and other labor laws. at p. Workers CompensationLawyers. In deciding whether an inmate was performing compulsory or voluntary work, trial courts may ask the following questions (the Rowland factors): (1) Did the county require the worker to work as a condition of incarceration? California workers compensation laws hold all employers must carry workers compensation insurance to reimburse injured workers for one-time industrial accidents or repetitive stress injuries. [T]he language in a local ordinance with respect to assigning work to inmates is not determinative, although it may be considered in determining whether the inmate's work is compulsory or voluntary. OD LEGAL LOS ANGELES . California Unemployment Insurance Appeals Board | The California Unemployment Insurance Appeals Board has a long tradition of protecting the rights of employers and unemployed or disabled workers. The WCAB has several conclusions it may reach in deciding an appeal. Long Beach Workers' Compensation Appeal Board. I, 6 [Slavery is prohibited. The standard rating is adjusted for age by lowering the rating for younger workers and increasing it for older workers on the theory that it is easier for younger people to adjust to a permanent handicap. Industries held that even if only one type of benefit was delayed the penalty applied to all awarded benefits. The maximum voucher amount is $10,000. To assist injured workers in the fair, equitable, and expeditious resolution of workers compensation claim issues. (1970) 10 Cal.App.3d 655, 89 Cal.Rptr. Copyright 2023, Thomson Reuters. (1979) 94 Cal.App.3d 250, 156 Cal.Rptr. (See Pen. For dates of injury on or after Jan. 1, 2003, injured workers who have legal representation may settle vocational rehabilitation for a lump sum. ), Thus, workers compensation protections differ between state inmates, county inmates, and county inmates working in fire suppression. CITY OF LOS ANGELES, a Municipal Corporation, Petitioner, v. WORKERS' COMPENSATION APPEALS BOARD of the State of California, Charles Calvert, et al., Respondents. (1979) 23 Cal.3d 815, 153 Cal.Rptr. The WCAB acknowledged this dilemma. The court lobby will be open 30 minutes before the beginning of the court session. (https://www.nbcbayarea.com/news/california/california-nevada-forced-prison-labor-servitude/3158526/.) If you have any questions about a work injury, a workers compensation claim that is already on file or might exist, please contact our office at 1-877-525-0700. (County of Los Angeles v. Workmen's Comp. LEXIS 3119] (writ denied). Box 429459 San Francisco, CA 94142-9459. . No food, gum or drink (other than bottled water) is allowed on the 3rd floor in the hallways, lobbies or courtrooms. Individual courses and subscriptions available. If the employee has predesignated a physician, can I refer the employee to a facility listed in the County provided Initial Treatment Center Directory first? A Los Angeles workers compensation attorney can help ensure your claim is fairly administered from the onset and help ensure you get the compensation you and your family need to survive. . What are the Workers Compensation Laws in California? POSITION: The Workers' Compensation Division of the Office of the City Attorney has immediate openings for one or more attorneys. (Rowland, 220 Cal.App.3d at pp. California Workers' Compensation Telephone Directory Division of Workers Compensation: 800-794-6900 DWC - San Francisco (Headquarters): 415-703-5011 DWC - Bakersfield: 661-395-2723 DWC - El Centro: 760-353-0607 DWC - Long Beach: 562-590-5001 After 60 days, the WCAB must come to a decision on the appeal or it will be denied. The test is whether the county inmate worker volunteered to work or was forced to work as an incident of incarceration. 51.) You likely need counsel and protection from a skilled, knowledgeable California workers' compensation attorney if: Perhaps the most important reason to hire a workers' compensation lawyer is that your ability get proper medical care for your work injury and achieve maximum recovery may depend on it. Why hire a workers' compensation lawyer and when is it necessary? The Board assessed the penalty as $1,370. If the employee has predesignated a personal physician to treat an on-the-job injury or illness, and it is not an emergency, the employee should go to this predesignated physician. Public Agency Risk Managers Association (PARMA), California Division of Workers Compensation, Los Angeles County District Attorneys Office. We also provide meeting space for workers compensation clients in Hollywood and . htj0_RYr_HW:d`qIoGl4v;H|"A!8x~!o)tC=z{CsZcDesV\d'mwfp,7W(hk2h2*Y{t%|A*98]y|Ig.t3^z>1f3%~fi$*x-1wK1o/ j~
4720 Lincoln Boulevard, 2nd floor Marina del Rey, CA 90292-6902 (visit the website) WCAB MAIN PHONE NUMBER. This includes investigating workers compensation claims, determining entitlements, issuing notices, and delivering benefits within with statutory timeframes. While no one envisions having vital medical care reimbursement and compensation for lost wages denied by a system designed to protect injured workers and their families, much less suffer a workplace injury in the first place, the reality is many workers must have their cases heard in front of the WCAB. 3d 1, 416 P.3d 1]andS. G. Borello & Sons, Inc. v. Dept. Departments may require supervisors to complete incident reports documenting when, how, and what occurred. The former and latter are statutorily protected. WORKERS' COMPENSATION APPEALS BOARD [LAO] 320 W. 4. th. Not a Lexis+ subscriber? The purpose of the Return-to-Work Unit (RTW) is to provide a standardized procedure to aid RTW coordinators, supervisors and managers in implementing RTW principles in their efforts to assist injured/ill employees to return to work and manage their cases. Recognized by Southern California Super Lawyers. County inmates who did not work in fire suppression are at the mercy of this voluntary / compulsory test. Public Alerts, Accessibility In cases where suffering workers have their claims denied, it may be necessary to adjudicate their claims through a workers compensation judge. Supp.1979) s 11.12, pp. Once a person enters a prison and surrenders his freedom, he is bound by strict rules with respect to housing, personal belongings, visitation rights, and personal movement. This service is available 24 hours, 7 days per week, and will transmit the information received by the department to the appropriate workers compensation third party administrator within one working day. ), Listing of cases pending on appellate grant, WCABs Final Rules in Effect as of January 1, WCAB Issues Notice of September 24 Public Hearing on Proposed Amendments to its Rules of Practice and Procedure, Review en banc & significant panel decisions, Review listing of cases pending on appellate grant, Licensing, registrations, certifications & permits. The penalty does not apply to the permanent disability advances voluntarily and timely paid commencing on July 11, 1977 until the issuance of the findings and award. DO NOT RELY ON THIS WEBSITE FOR LEGAL ADVICE. The penalty does apply to the permanent disability payments actually delayed and those which are payable pursuant to the issued findings and award of June 9, 1978. One of California's preeminent workers' compensation attorneys in Los Angeles fighting exclusively for injured workers. Los Angeles, CA 90010 +213-739-7000. Const., art. (1966) 241 Cal.App.2d 15, 50 Cal.Rptr. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. WCAB ADDRESS. Appeals Bd. The judge also found that as County had unreasonably delayed in making permanent disability payments to Crowe a ten percent penalty should be assessed against County on the awarded permanent disability (including the life pension) and on the awarded future medical treatment. Walk-through hours are 8:00 a.m. to 11:00 a.m. and 1:00 p.m. to 4:00 p.m. Monday through Friday. LOS ANGELES . P.D. Civ . This raises equal protection considerations, especially in circumstances when the court has the discretion to punish some crimes by imprisonment in state prison or county jail. Certain classes of County employees are entitled to statutorily derived benefits that exceed the state temporary disability rate. 823-824, 153 Cal.Rptr. . Read the Court's full decision on FindLaw. The California Workers' Compensation Appeal Board is an important entity all Los Angeles workers should be aware of.While no one envisions having vital medical care reimbursement and compensation for lost wages denied by a system designed to protect injured workers and their families, much less suffer a workplace injury in the first place, the reality is many workers must have their cases . At the hearing the parties stipulated to permanent disability of 421/2 percent, equivalent to a total of $13,702.50 in weekly payments. What If Im a Passenger in a Car Accident? (213) 351-6405 51; disapproved on another point in Adams v. Workers' Comp. Vocational rehabilitation does not apply for dates of injury after Jan. 1, 2004. endstream
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However, in March 1977 the parties settled by an appeals board approved compromise and release the claim for penalty for any delay by County on or before March 28, 1977. If you have this concern, contact your workers compensation third party administrator claims examiner. The Workers Compensation Claim Management Unit (WCCMU) operates and monitors a complete permissibly self-insured workers compensation program ensuring the full provision of benefits under the law to employees whose injuries arose in the course and scope of employment. The purpose of the following material is to provide department managers and supervisors a general guide for reporting industrial injuries/illnesses. . Generally, the employer controls the medical treatment for the first 30 days after the injury is reported, and the employee is then free to select any treating physician or facility. (https://apnews.com/article/2022-midterm-elections-slavery-on-ballot-561268e344f17d8562939cde301d2cbf.) Document your concerns to the workers compensation third party administrator. At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. . COUNTY OF LOS ANGELES v. WORKERS COMPENSATION APPEALS BOARD. The WCCMU provides continuous on-site workers compensation third party administration contract monitoring. endstream
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ataras@ceo.lacounty.gov, Joe Carrillo P.D. State inmates are statutorily included in the definition of employee while county inmates are subjected to a compulsory test to determine their employee status. Some people do become victims of wrongful termination because they have been injured and filed a claim. The applicants in Garcia wish to file a civil suit, where the value of the potential civil damages is greater than the potential value of the workers compensation benefits. The carrier made no delay in the payment of the awarded temporary disability. "y At the time of injury Labor Code section 4658 provided:If the injury causes permanent disability, the percentage of disability to total disability shall be determined and the disability payment computed and allowed according to the following schedule:c3Percentage of averagec3weekly earningsc3allowed for remainderc2Number of weeksof life after periodc1Percentage ofc2for which 65 percentc3for which 65 percentc1permanentc2of average weeklyc3of average weeklyc1disability incurredc2earnings allowedc3earnings allowed 140104002080030120040160050200060240070280158032030903604510040060(Stats.1937, c. 90, p. 283, s 4658. What are department workers' compensation posting requirements? Appeals Bd., supra, 18 Cal.3d at p. 231, 133 Cal.Rptr. Total costs for rehabilitation are now limited to $16,000 for workers injured on or after Jan. 1, 1994. Relations(1989) 48 Cal.3d 341 [256 Cal. (Gallamore, supra, 23 Cal.3d at pp. LEXIS 352].). LOS ANGELES WORKERS' COMPENSATION APPEALS BOARD [LAO] 320 W. 4th Street, 9th Floor Los Angeles, CA 90013-1105 Telephone: (213) 576-7335 JUDGE Workers' Compensation Appeals Board (WCAB) Industrial Welfare Commission (IWC) Search; Custom Google Search Submit. The Workers Compensation Appeals Board (WCAB) exercises all judicial powers vested by the Labor Code in a reasonable and sound manner and provides guidance and leadership to the workers' compensation community through case opinions and regulations. 2, 100 Cal.Rptr. We are taking calls from injured workers on matters involving the Los Angeles Workers Compensation Appeals Board, Van Nuys Workers Compensation Appeals Board, Long Beach Workers Compensation Appeals Board, Marina Del Rey Workers Compensation Appeals Board, Pomona Workers Compensation Appeals Board, click here for Oxnard Workers Compensation Appeals Board, Anaheim Workers Compensation Appeals Board, click here for Santa Ana Workers Compensation Appeals Board, click here for and Bakersfield Workers Compensation Appeals Board. THE MATERIALS CONTAINED IN THIS WEBSITE ARE FOR INFORMATIONAL PURPOSES AND ARE NOT TO BE CONSIDERED ADVERTISING OR LEGAL ADVICE. Units within the Marina del Rey district office: Zip code locator tool will help you locate the DWC district office serving your ZIP code. If you were injured on the job, do not put your claim at risk by attempting to negotiate with workers compensation claims adjusters by yourself. It stated, . Appeals Bd. Ins. If they succeed, presumably the compulsory part of the voluntary / compulsory test will be gone, making all inmate work voluntary. The penalty is annulled as it applies to the award of further medical care and to the timely, voluntary permanent disability benefits paid prior to the issuance of the permanent disability award. Workers compensation claims are handled from the onset by insurance adjusters who may have best interests of their insurance company at heart, rather than the victim. On December 14, 1975, while at home applicant sustained a myocardial . Our Los Angeles offices are located in downtown Los Angeles and Sherman Oaks. (1972) 27 Cal.App.3d 504, 104 Cal.Rptr. We are also cognizant of the difference between county inmates who work in fire suppression and countyinmates who do not, the former being statutorily included in the definition of employee, while the latter being subjected to the aforementioned compulsory test. These are the only numbers that we are aware of and have available for California Workers' Compensation. Rules and regulations of the California Division of Industrial Accidents and Workers' Compensation Appeals Board Standard claims evaluation techniques, references, and settlements . What if I am worried that the employee is not able to safely handle the normal duties after an injury? Fund v. Workmen's Comp. Appeals Bd. F085705 and F085713, arguing that that the inmate workers did not receive compensation for their work and therefore cannot be deemed employees protected by workers compensation. Lastly, we are aware that in more recent laws, employer control is a big factor in determining employment status (the more employer control, the more likely employment status is found [fn 5: SeeDynamex Operations W. v. Superior Court(2018), (Garcia, supra; Moreno, supra; Ciprian, supra; Brown, supra. The Permanent Disability Rating Schedule specifies standard percentage ratings for permanent impairments and limitations, and provides for the modification of these standard ratings based on the injured workers age, occupation, and considers the employees diminished future earning capacity. No. 2, 133 Cal.Rptr. CITY OF LOS ANGELES, a municipal corporation, legally uninsured, Petitioner, v. WORKERS' COMPENSATION APPEALS BOARD OF the STATE OF CALIFORNIA; Morris Rivard, Respondents. [T]he language in a local ordinance with respect to assigning work to inmates is not determinative, although it may be considered in determining whether the inmate's work is compulsory or voluntary. Items may be date stamped and filed at the information desk in the lobby. The Workers' Compensation Appeals Board, a seven-member, judicial body appointed by the Governor and confirmed by the Senate, exercises all judicial powers vested in it by the Labor Code. What this means in terms of labor protections for inmate workers, though, remains to be seen. All visitors of the court must park in the paid parking area for $15.50 per day. Those with a permanent partial disability of 70 percent or more also receive a small life pension a maximum of $257.69 per week following the final payment of permanent partial disability benefits. County of Los Angeles . Wrk. Click to share on Twitter (Opens in new window), Click to share on Facebook (Opens in new window), Click to share on Google+ (Opens in new window), How to Prove Injuries in a Los Angeles Car Accident. h27Q0Pw/+Q0L)6 App. The benefits are generally designed to replace two-thirds of the lost wages, up to a maximum of $840 per week. 757.) h, Do I Have to Take Time Off for a Work Injury? When this fails, workers have the right to take their appeals to the WCAB. 543, 769 P.2d 399, 54 Cal.Comp.Cases 80]], whereas here, the opposite effect results when applying the compulsory test, in that the more control the county exercises, the more likely the inmate's work is found to be compulsory of incarceration without the protections of an employment relationship. . State Fund was the workers' compensation insurer for L.A. School District up through June 30, 1976; thereafter, L.A. School District was permissibly self-insured. (1976) 18 Cal.3d 226, 133 Cal.Rptr. An employer must provide an employee a Workers Compensation Claim Form (DWC-1) within one working day of receiving notice of an industrial injury/illness. But this special carve-out is only limited to county inmates working in fire suppression. ANY REFERENCE OR LINK TO A THIRD PARTY FOUND ON OUR INTERNET SITE IS NOT AN EXPRESS OR IMPLIED ENDORSEMENT BY US TO THAT THIRD PARTY OR THE INFORMATION PROVIDED. What if my employee has a cut or scratch, something that only requires antiseptic and a bandage? The Supervisory Investigation Report can be a useful tool in preventing like type injuries from occurring in the future. Wrk. Appeals Bd. San Diego +619-763-1137 . Appeals Bd. }. Gallamore expressly held that the penalty is to be computed by assessing 10 percent of the entire amount ultimately awarded for the particular class of benefit which has been unreasonably delayed or withheld. (23 Cal.3d at p. 827, 153 Cal.Rptr. arossi@ceo.lacounty.gov, Tony Taras To speak to one of our Los Angeles labor lawyers call either: 323-525-1600, 310-842-8600, or 818-783-7300. 400, the court commented that It seems reasonably safe to conclude that there may be an exception to the Gallamore rule where the benefit which is unreasonably delayed (e. g., medical treatment) is not a direct monetary payment to the injured worker and, to be effective, the penalty must be assessed against some reasonably related benefit (e. g., temporary disability) which is part of the same award. It has been argued that this statement in Lorenz Bauer appear(s) contrary to the explicit holding in Gallamore that the penalty applies against the class of benefits ultimately awarded in which the delay occurred. (10-Percent Penalty Under Labor Code s 5814 Court Redrafts Opinion Assessing Penalty Against Delayed Benefits, in Light of Gallamore (1979) 7 Cal.Workers' Comp.Rptr. The following schedule is illustrative of the computation of the number of benefit weeks:Column 1Percentage ofl2Column 2Cumulative numberpermanent disability incurred:l2of benefit weeks:515.001030.251550.252070.502595.5030120.7535150.7540180.7545210.7550241.0055276.0060311.0065346.0070381.2575421.2580461.2585501.2590541.2595581.25100for life(b) Two-thirds of the average weekly earnings for four weeks for each 1 percent of disability, where, for the purposes of this subdivision, the average weekly earnings shall be taken at not more than seventy-eight dollars and seventy-five cents ($78.75).Labor Code section 4659 as added by Statutes 1971, chapter 1750, section 5.7, operative April 1, 1972, and amended by Statutes 1973, chapter 1023, page 2030, section 7, operative April 1, 1974, presently provides:(a) If the permanent disability is at least 70 percent but less than 100 percent, 1.5 percent of the average weekly earnings for each 1 percent of disability in excess of 60 percent is to be paid during the remainder of life, after payment for the maximum number of weeks specified in Section 4658 has been made. Bd. More significantly, Gallamore cites Manning as one of the cases (the others being Garcia; Sturm, supra, 35 Cal.App.3d 374, 110 Cal.Rptr. In the recent case of Lorenz Bauer v. Workers' Comp. The Workers' Compensation Appeals Board is comprised of three judges appointed by the Governor and is separate from the Court of Workers' Compensation Claims. THE CONTENT ON THIS WEBSITE IS ONLY INTENDED TO RELATE TO CALIFORNIA LAW. The judge's decision, called a Findings and Award, may provide for future medical care, and may be reopened within five years of the date of the injury. (U.S. We have workers compensation lawyers capable of handling both the big and small workers compensation case. It stated, We recognize that the relationship between a correctional officer and an inmate is unique and distinct from that of an ordinary employer and employee. Report this profile; About. App. This should not be used for legal research but instead can be used to find solutions that will help you do legal research. The judge rejected County's contention that the penalty only applied to benefits actually delayed. A judge at the Workers' Compensation Appeals Board (WCAB) decides claims. Hire a competent workers compensation lawyer to help you through your work injury. Filing the paperwork promptly expedites the compensability determination and benefits all parties. Civ. ANAHEIM WORKERS' COMPENSATION APPEALS BOARD [AHM] 1065 North Link, Suite 170 Anaheim, CA 92806 Telephone: (714) 414-1800 JUDGE Jamie Spitzer [Presiding] . Within 15 days of the appeal, the judge whose ruling is being questioned may submit a report to the WCAB detailing his or her reasoning on the claims denial. The WCAB further recognized that this voluntary / compulsory test may be difficult to apply. The carrier for the employer failed to make any permanent disability advances until after the injured had filed a petition for assessment of a penalty. The CEO Risk Management Branch acknowledges; the California Division of Workers Compensation, California Commission on Health and Safety and Workers Compensation, Institute of Industrial Relations University of California at Berkeley, and the Labor Occupational Health Program, School of Public Health University of California at Berkeley for providing material that has been incorporated into this website. No. Camarillo +805-377-0633. Partner lawyers, Scott Ford and Cheryl Wallach are honored throughout the State of California for their advocacy on behalf of injured workers. As of February 2023, however, California lawmakers are advancing legislation to end forced labor as a punishment for crime. 1 2 3 Popular Pages These regulations were filed with the Secretary of State on February 1, 2023, and are effective on April 1, 2023 Board Members Home; . This is a nontransferable voucher for education-related retraining or skill enhancement, or both, payable to a state approved or accredited school if the worker is injured on or after Jan. 1, 2004. Amended by Stats.1949, c. 1583, p. 2883, s 1; Stats.1959, c. 1189, p. 3280, s 13. THIS IS A WEBSITE FOR A CALIFORNIA LAW FIRM. Electronic Reporting System for Doctors First Report of Injury, Licensing, registrations, certifications & permits, Workshops are held via Zoom at 3 p.m. on the first Friday of every month in. EUREKA WORKERS' COMPENSATION APPEALS BOARD [EUR] 409 "K" Street, Room 201 Eureka, CA 95501 Telephone: (707) 441-5723 *SATTELITE OFFICE - Do not send mail . The matter proceeded to hearing on May 24, 1978. Title: 230228 LOPEZ CANSINOS ADJ9937224, ADJ9937229 Author: WCAB Created Date: )IcRYZlg` jo
Therefore, it is recommended every manager and supervisor become familiar with their departments industrial injury/illness reporting practices. For more than 70 years, Hanna Brophy has represented insurance companies, permissibly self-insured employers, and governmental entities in all litigation before the Workers' Compensation Appeals Board. ~w1njg]4
Permanent partial disability benefits are also payable at two-thirds of the injured workers average weekly wages, but are subject to a much lower maximum. INTERNET SUBSCRIBERS AND ONLINE READERS SHOULD NOT ACT UPON THIS INFORMATION WITHOUT SEEKING PROFESSIONAL COUNSEL. Free Consultations & We're Available 24/7. (Duke) (1974) 39 Cal.Comp.Cases 809.) (Duke) (1974) 39 Cal.Comp.Cases 809.) Industries v. Workers' Comp. (Garcia, Castaneda, Chaparro v. County of Fresno (December 30, 2022) [2022 Cal. 1979) s 17.06(1), p. (1981) 126 Cal.App.3d 629 [46 Cal.Comp.Cases 1304]; Morales v. Workers Comp. |J+RSeO\$>_LJrA