California 1st Orders Reallocation of Settlement

In an opinion not designated for publication, the First District of the California Court of Appeals ordered a reallocation of settlement proceeds from a loss of consortium claim that were structured to defeat a carrier's credit rights. In CNA Casualty of California v. WCAB (Kirkeby), No. A111297, 02/27/2006, David Kirkeby was injured in a car accident caused by the negligence of a third person while working for Quest Micro Services (Quest) in 1999. Kirkeby suffered a soft injury strain, which caused no obvious injury, but he underwent surgery to address problems that subsequently arose...