Bowen v. Workers' Compensation Appeals Board

I concur in the majority opinion, which masterfully and comprehensively reviews the authorities bearing on this important issue. I concur separately simply to note that the course of case law development in this area has unnecessarily complicated the law, and that the detailed contractual analyses presented in the briefs, to which the majority opinion properly responds, should not be necessary in every future case.

Labor Code section 3600.5 appears in chapter 3 of part 1 (“Conditions of Compensation Liability”). It provides that an employee injured out of state during the course of his…