February 25, 2025 | Sacramento, CA — MedLegalNews.com — 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.
🔗 Source: CSC
Stay updated on employment law, workers’ compensation, and medical-legal news at MedLegalNews.com.
🔗 Read More from MedLegalNews.com:
- New York Doctor Convicted in $24M Medicare Fraud Scheme
- WCIRB Unveils 2025 Leadership Address as Andrea Coleman Takes the Helm
- Florida Businessman Sentenced to 48 Months for Migrant Labor Scheme and Worker Death
- Louisiana Doctor Sentenced to 87 Months for Illegally Prescribing 1.8 Million Opioid Doses
- California Cites Amity In-Home Care $2.3 Million for Misclassifying Caregivers
FAQs: California Supreme Court Decision
What did the California Supreme Court decide in the Ayala case?
The Court ruled that industrial disability leave (IDL) benefits do not qualify as “compensation” under Labor Code Section 4553, meaning they are not eligible for the 50% penalty increase applied to serious and willful misconduct claims.
Why are IDL benefits excluded from penalty increases?
The California Supreme Court clarified that penalties for serious and willful employer misconduct apply only to temporary disability benefits. Justices found that IDL benefits fall under the Government Code rather than the Labor Code, distinguishing them from temporary disability benefits that can receive penalty enhancements.
How does this decision impact public employees?
The California Supreme Court held that IDL benefits fall under the Government Code rather than the Labor Code, excluding them from penalty enhancements under Section 4553. The ruling clarifies that while IDL benefits are excluded from penalty increases, temporary disability benefits remain protected under Section 4553, ensuring public workers can still pursue additional compensation for proven employer misconduct.
What precedent does this case establish for future workers’ compensation claims?
This decision reinforces that penalties under Section 4553 apply only to benefits directly governed by the Labor Code, setting a clearer boundary between IDL and workers’ compensation entitlements.