County of Alameda v. Workers' Compensation Appeals Board
151 Cal. Rptr. 3d 920
Cal. Ct. App.2013Background
- Knittel, a deputy sheriff, injured his knee on September 13, 2009, and the County began paying disability benefits from the date of injury.
- For the first year, Knittel received section 4850 salary continuation benefits in lieu of temporary disability payments.
- After the first year, the County paid regular temporary disability indemnity for another year.
- The County then stopped payments, citing the 104-week aggregate limit for temporary disability under § 4656, subd. (c)(2).
- The WCJ ruled that section 4850 benefits do not count toward the 104-week limit; the WCAB denied reconsideration; the Supreme Court granted review to resolve statutory interpretation affecting public safety officers.
- The Court held that aggregate disability payments include 4850 benefits paid for temporary disability and count toward the 104-week limit, remanding for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 4850 salary continuation counts toward the 104-week limit | Knittel argues 4850 benefits are not temporary disability and do not count | County argues 4850 benefits are workers’ compensation benefits and count toward aggregate payments | Yes; 4850 benefits count toward the 104-week limit absent a specific exclusion |
Key Cases Cited
- Boyd v. City of Santa Ana, 6 Cal.3d 393 (1971) (payments characterized as workers’ compensation benefits)
- City of Martinez v. Workers’ Comp. Appeals Bd., 85 Cal.App.4th 601 (2000) (temporary disability benefits framework and timing)
- Brooks v. Workers’ Comp. Appeals Bd., 161 Cal.App.4th 1522 (2008) (aggregate disability payments can include non-temporary-disability benefits)
- Mt. Diablo Unified School Dist. v. Workers’ Comp. Appeals Bd., 165 Cal.App.4th 1154 (2008) (Education Code benefits triggered 104-week limit considerations)
- Los Angeles County Prof. Peace Officers’ Assn. v. County of Los Angeles, 115 Cal.App.4th 866 (2004) (recognizes 4850-like benefits as workers’ compensation benefits)
- State Compensation Ins. Fund v. Workmen’s Comp. Appeals Bd., 26 Cal.App.3d 200 (1972) (historical context on compensation benefit payments)