3rd DCA: TTD Benefits Should Run Concurrently, Not Consecutively

In a rare case involving two injuries that caused a total temporary disability, the 3rd District Court of Appeal ruled that the two-year limitation for total temporary disability benefits runs concurrently, pursuant to the intent of Senate Bill 899.In Foster v. WCAB, No. C056820, 4/17/08, the appellate court examined the statute that limits temporary total disability benefits to 104 weeks, and applied it to a case where a worker's two distinct injuries caused total temporary disability. The statute is Labor Code 4656(c)(1). The court's decision rendered the defense, Zurich American Ins...