Sanders v. General Motors Corp.

Plaintiff appeals a ruling of the Workmen’s Compensation Appeal Board (WCAB) that an earlier Workmen’s Compensation Bureau (Bureau) determination that she was not totally and permanently disabled 1 bars a renewed claim by the plaintiff unless she can show that her condition has changed for the worse since the first determination. We must decide whether the WCAB has properly applied the doctrine of res judicata in this instance.

The plaintiff injured her back in 1960, but continued working until 1963, at which point her back condition degenerated to the extent that she could no longer work. The…