Sullivan: May 2016 Case Law Update

Jurisdiction and subrogation In Collazo v. Global Manufacturing (2016 Cal. Wrk. Comp. P.D. LEXIS 86), the Workers' Compensation Appeals Board held that a defendant was not entitled to a credit from an applicant's civil settlement when it was not clear from the record whether the applicant's settlement was based solely on the power-press exception under LC 4558. It explained that a defendant must prove what portion of the applicant's civil settlement was subject to credit. Injury In Arias v. City of Los Angeles (2016 Cal. Wrk. Comp. P.D. LEXIS 83), the WCAB upheld an...