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Case Name Sanchez v. County of Los Angeles
Date 10/26/2005
Note Apportionment for permanent disabilities to the same body region required only where the applicant fails to disprove overlap.
Citation 70 CCC 1440
WCC Citation WCC 31302005 CA
WORKERS' COMPENSATION APPEALS BOARD STATE OF CALIFORNIA Case No. MON 0307506 OPINION AND DECISION AFTER RECONSIDERATION (EN BANC) VIRGINIA SANCHEZ, Applicant, vs. COUNTY OF LOS ANGELES, Permissibly Self-Insured; and TRISTAR RISK MANAGEMENT (Adjusting Agent), Defendant(s). BACKGROUND Virginia Sanchez (applicant) sustained an industrial injury to her left foot on December 18, 2002, while employed as a deputy sheriff by the County of Los Angeles (defendant). The apportionment of pre-existing permanent disability has been a fixture of California workers' compensation law since its inception. In any event, verification is not required when the defendant is the state, a county, a city or other specified public entity. We recognize that, often, the applicant may satisfy this burden by establishing the factors of disability underlying the prior permanent disability award.

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