Christine Baker, as Administrator v. Workers’ Compensation Appeals Board and X.s., Respondents

Summary

The court held that Labor Code section 4659(c) requires cost-of-living increases for qualifying total permanent disability and life pension benefits to begin prospectively on the January 1 following the date the worker becomes entitled to and actually begins receiving the applicable benefit. It rejected both injury-date-based retroactivity and retroactivity to January 1, 2004, because those interpretations disregarded the statute's references to an existing payment and entitlement to receive it and produced unwarranted or duplicative inflation adjustments. The judgment annulling the agency decision was reversed and the matter was remanded.