Yesterday the Court of Appeal, Fourth Appellate District, issued its ruling in California Highway Patrol vs. WCAB (D036792 - 6/12/01), holding that where a carrier makes a late payment and fails to include interest in that payment, only a single penalty may be imposed under Labor Code section 5814.
Basing its holding on Christian v. Workers' Comp. Appeals Bd., 15 Cal.4th 505, the court found that the failure to pay interest on the retroactive payment was improper because the 'failure to act timely in payment of permanent disability and interest was a single act, not separate and distinct acts...
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