California Insurance Guarantee Ass'n v. Workers' Compensation Appeals Board

Opinion

ALDRICH, J.

INTRODUCTION

After the Employment Development Department (the EDD) paid temporary unemployment compensation disability (UCD) benefits to a disabled worker, it filed a lien claim for reimbursement from the employer’s insolvent workers’ compensation carrier. California Insurance Guarantee Association (CIGA) assumed the insolvent carrier’s obligations, but refused to satisfy the EDO’s hen. CIGA argued it is only required to pay a “covered claim” and the EDO’s lien is an obligation to a state that is excluded from the definition of “covered claims.” (Ins. Code, § 1063.1, subd.…