Disability Law

Overview of Workers’ Compensation in California

Significant changes have been made to California's Workers' Compensation system.
Please read summary of SB 899 for details.

Workers’ compensation insurance was set up to provide compensation to employees for work-related injuries and illnesses, including medical treatment costs, temporary payment for lost wages, and permanent disability payments to compensate for decreased ability to compete in the open labor market. 

Workers' compensation in United States began in the early 1900's.  Before then, employees could pursue civil court actions against employers who were often protected by anti-employee legal rules. These rules began to collapse after the 1911 Triangle Shirtwaist Factory fire in New York City.  Employers, seeing increased jury awards against them, began to support workers' compensation systems that they had been rejecting for half a century.

Workers' compensation offers what has been called “historic compromise.”  Employees give up the right to pursue large monetary, fault-based awards in exchange for a guarantee of prompt delivery of lower no-fault benefits.  The injury must be work-related, but the employer need not have been “at fault.”  The employer is required to pay benefits as long as the injury arose out of employment (AOE) and in the course of employment (COE).  In California, a safe workplace and workers' compensation insurance for workplace injuries are rights guaranteed in Article 14, Section 4 of the State Constitution. 

The California Department of Industrial Relations (DIR) administers workers' compensation.  Within the DIR is the Workers' Compensation Appeals Board (WCAB). This Board is a judicial body made up of seven commissioners, five of whom are attorneys.  A disputed case is argued before an administrative law judge.  It can be appealed to the full Board.  In special cases, a decision can be appealed to a state intermediate court of appeal.  The award for total disability is only $490 per week - or less.  There is no limit on expenditures for treatment expenses.  Vocational rehabilitation services are capped at $16,000. In the event of death, the maximum award to the family is $160,000 depending on the number of dependents left behind. 

An injured employee is required to inform the employer within 30 days of the "date of injury."  At this point, the employer has only 24 hours to notify the State.  The employee has a right to pre-designate a personal physician who will provide treatment in the event of occupational illness or injury.  If she does not, the employer has the right to designate the treating physician or clinic.  As treatment for a work injury anticipates medical-legal reports to third parties which impact the employer's insurance rates, the confidentiality of the worker’s medical record is limited.  The employee, is however, protected from retaliation for claiming the injury.  The Americans With Disabilities Act and the California Fair Employment and Housing Act provide additional protections.

The burden of proof is on the party trying to establish some point by a preponderance of the evidence.  A preponderance of the evidence is that amount of evidence which tends to prove a fact in dispute more likely than not.  The injured worker has the burden to prove that the injury or medical condition arises out of and in the course of employment.  Once the injured worker has proved that the injury arose from the employment, all applicable laws "shall be liberally construed by the courts with the purpose of extending the benefits for the protection of persons injured in the course of their employment."  All judicial decisions must be based on “substantial evidence.”  An inaccurate medical report is not substantial evidence as a matter of law.

There must be an employment relationship.  There must be an injury.  The injury must have been caused by employment.  The injury must also occur in the course of that employment.  The injury may be specific or “cumulative.”  It may be physical, physical-mental or mental-mental. 

In order for “condition” to be considered an injury, it must ether cause work disability or result in need for medical treatment.  When an injury aggravates a previously existing non-industrial disability, the concept of apportionment arises.  In such cases, the "tape must be rewound” and the pre-existing disability must be rated and then subtracted from the current disability.  The date of injury in a cumulative injury situation is the date when the employee first suffered work disability or either new or should have known that the disability was caused by present or previous employment. 

The causation analysis is: What is the diagnosis?  What is the work exposure?  What other causes of disability might be present other than work?  The focus is on disability rather than on diagnosis.  In general, work activities need not be the sole cause of an injury, or even the primary cause in physical-physical or physical-mental claims.  In mental-mental claims, however, actual events of employment must be the predominant cause of the injury.  This 50 percent rule is reduced to 35 percent when injury results from a violent act.  Also, psychiatric injury is not compensable unless the employee was employed six months.  This does not apply if the injury was caused by an extraordinary event.  A lawful, non-discriminatory, good faith personnel action does not provide a basis for a claim of psychiatric injury. 

In the case of job stress, the focus is not on how much stress should be felt by the employee based on a normal reaction to events but how much stress actually is felt by the individual worker reacting uniquely to the work environment.  However, there has to be something more than imagined stress.  The employment must be a positive factor influencing the course of the disease.  The employment cannot be a mere passive element that a non-industrial condition happened to focus on, nor may the employee's duties merely provide a stage for the injury. 

Claims filed after notification of termination or layoff are not allowed unless one of the following conditions are met; sudden or extraordinary event, employer had notice of the injury before the notice of termination, medical record existing before the termination or layoff contains evidence of treatment of the injury, a trier of fact finds that there was sexual or racial harassment, or there is evidence that the date of injury is subsequent to the date of notice of termination but before the effective date of that notice.

Emotional ability, loss of concentration and problems thinking constitute loss of function.  Loss of function implies impairment.  Disability is the inability as a result of impairment to compete in the open labor market.  The open labor market consists of all jobs or occupations, not just the injured worker's usual and customary occupation.  Impairment can cause disability even though it does not prevent the injured worker from doing his or her present job. 

There are four categories, also called factors of disability that must be covered in a disability evaluation: objective factors, subjective factors, work restrictions, and loss of pre-injury capacity.  Objective factors are those that can be directly measured, observed, or demonstrated.  Subjective factors cannot be measured or observed.  Emotional factors are typically subjective factors.  A factor is considered ratable if it interferes with the worker's ability to compete in the open labor market. 

If there is a mental condition that handicaps the applicant in competing in the open labor market and the disability has a relationship to work and the worker’s condition is permanent and stationary, there must be an evaluation of permanent psychiatric disability as follows:  a multi-axial diagnosis, a list of disabling symptoms and whether each is constant, intermittent, or occasional in frequency, and opinion as to the level of impairment (minimal, very slight, slight, moderate, severe) of each disabling symptom with respect to  eight statutory work functions.  The eight work functions are: the ability to comprehend and follow directions, the ability to perform simple and repetitive tasks, the ability to maintain a work place appropriate to a given workload, the ability to perform complex or varied tasks, the ability to relate to other people beyond giving and receiving instructions, the ability to influence people, the ability to make generalizations, evaluations or decisions without immediate supervision, and the ability to accept and carry out responsibility for direction, control, and planning.

Americans with Disabilities Act (ADA)

The Americans with Disabilities Act prohibits discrimination in employment against any “qualified individual with a disability” and requires employers to provide "reasonable accommodation" that will enable the individual to function in the job.  Almost identical language is found in the California Fair Employment and Housing Act.  These laws go beyond workers' compensation laws to require job modification or provision for alternative work.  A qualified individual with a disability is defined as someone who meets one of the following criteria but who can perform the essential functions of the employment position with or without reasonable accommodation.  A physical or mental impairment that (even when treated) substantially limits one or more major life activities or a record of such impairment or are regarded as having such impairment.  Fundamental job duties do not include incidental duties or functions.  Substantial limitation means an impairment that restricts the individual's ability to perform either a class of jobs, or a broader range of jobs in various classes, as compared to the average person having comparable training, skills, and abilities.  Reasonable accommodation implies removing barriers, restructuring the employee's job to remove non-essential functions, reassignment when feasible to duties that the employee can perform, and offering other positions which effectively eliminate essential functions when such positions already exists.

For the ADA to apply there must be an initial determination of whether an individual has a "disability" within the meaning of the statute. For a mental condition to be covered, two elements must be satisfied: the condition must be (i) a mental impairment that (ii) substantially limits one or more major life activities.   Personality traits are not protected.  Companies can enforce disciplinary rules against misconduct and apply them to disabled employees. Employees who are disruptive, menacing or violent are not protected by the ADA.  A disciplinary rule may be enforced even if the misconduct is caused by a mental disorder as long as (i) the employer prohibits such misconduct by all employees, and (ii) the rule is job-related and consistent with business necessity for the position in question.