Zenith Insurance v. Workers' Compensation Appeals Board

Opinion

WOODS, J.

Pursuant to the Legislature’s 2004 comprehensive reform of workers’ compensation under Senate Bill No. 899 (2003-2004 Reg. Sess.), a new schedule for rating permanent disabilities of injured workers was adopted and became effective on January 1, 2005. The Legislature also amended Labor Code section 4660, subdivision (d) (section 4660(d)), which provides that the new schedule applies prospectively to compensable injuries on or after the effective date, as well as to compensable claims arising before January 1, 2005, “when there has been either no comprehensive medical-legal…