February 25, 2025 – The California Supreme Court ruled that a prison correctional officer, Michael Ayala, cannot receive a 50% penalty increase on his industrial disability leave (IDL) benefits despite suffering severe injuries in a planned inmate attack.
The court determined that IDL benefits do not qualify as “compensation” under Labor Code Section 4553, which mandates increased benefits for serious and willful employer misconduct.
The Legal Dispute
Ayala argued that the 50% penalty should apply to his IDL benefits, which provide more generous coverage than temporary disability (TD) benefits. Initially, a workers’ compensation judge agreed that the Department of Corrections and Rehabilitation committed serious misconduct by ignoring a known threat. However, the judge limited the penalty to TD benefits rather than IDL.
The Workers’ Compensation Appeals Board (WCAB) later reversed this decision, ruling that the penalty should apply to the full IDL amount.
Supreme Court Ruling
The Supreme Court overturned the WCAB’s decision, affirming a lower court ruling. It held that:
- IDL benefits are governed by the Government Code, not the Labor Code.
- Labor Code Section 4553 applies only to benefits “recoverable” under workers’ compensation law, which excludes IDL.
California Supreme Court: Ayala claimed that IDL should be treated as TD because the Government Code defines it as “temporary disability.” The court rejected this argument, clarifying that the term refers only to the period of coverage, not the nature of the benefit.
Impact on Public Employees
The court also dismissed Ayala’s reliance on prior case law, including:
- Brooks v. WCAB (2008) – which involved TD duration limits but did not classify IDL as TD for all legal purposes.
- California v. WCAB (Ellison) (1996) – which established that penalties apply only to benefits payable under the Labor Code, excluding IDL.
Ayala argued that excluding IDL weakened Section 4553 protections for public employees. The court disagreed, noting that TD benefits remain eligible for the 50% penalty, ensuring injured public workers still receive additional compensation for employer misconduct.
Key Takeaway
The California Supreme Court’s decision clarifies that IDL benefits are distinct from workers’ compensation benefits under Labor Code Section 4553. As a result, the 50% penalty applies only to TD benefits, not IDL benefits governed by the Government Code.
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🔗 Source: CSC
