Forney v. Western States Plywood

Claimant appeals a decision of the Workers’ Compensation Board, which affirmed the referee and held that employer had acted within its authority in unilaterally recovering an overpayment of permanent partial disability by deducting the amount from payments of temporary total disability.

The parties have stipulated to the facts. Claimant was injured on January 21, 1974. A determination order was issued on July 20, 1976, awarding temporary total disability and 20 percent unscheduled permanent partial disability. Those awards were paid in full. On March 10, 1977, a second determination order was…