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Rene Thomas Folse, J.D., Ph.D. is affiliated with the Law Offices of Floyd Skeren Manukian Langevin, LLP in an of counsel position working closely with many of the firm's office locations. Mr. Folse earned his Undergraduate Degree from California State University, Long Beach, before going on to earn his Juris Doctorate Degree from the San Fernando College of Law. Mr. Folse also has the distinction of having earned his Masters of Arts Degree in Clinical Psychology as well as his Juris Doctorate Degree in clinical psychology. Prior to joining Floyd Skeren Manukian Langevin, Mr. Folse had the distinction of co-founding one of Southern California’s most reputable law firms, Miller & Folse, in 1974. Throughout his career, Mr. Folse has focused his attention on all aspects of workers' compensation litigation. Mr. Folse has acted as a Judge Pro Tem with the Workers' Compensation Appeals Board, has been appointed to numerous faculty and teaching positions and has co-authored a leading treatise discussing psychological injury claims. In addition to his many other accomplishments, Mr. Folse is a highly sought after speaker. Mr. Folse currently works with Floyd Skeren Manukian Langevin in an of counsel position assisting the firm in matters of complex litigation in all aspects of workers' compensation.

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The WorkCompAcademy is a full featured online learning experience. Our faculty includes the leading practitioners in the California Workers' Compensation Community. Our online curriculum covers all aspects of Workers' Compensation Claims, from basic concepts to advanced topics of value to experienced practitioners such as senior claims exectives, attorneys, and Qualified Medical Evaluators. Students can access classes any time, from any internet connected computer. Courses can be completed at an individualized pace.

WorkCompAcademy Recent California Developments


Judicial Developments

Jurisdiction Injury AOE-COE Insurance Coverage TD, PD - Apportionment COLA Medical Care/MPN Issues
Death Benefits Penalties and Extraordinary Remedies AME/QME, UR and SSSOP Medicare Set Asside Issues CIGA Litigation Practice and Procedure

Regulatory Developments

Audits ACOEM/MTUS QME Regs CMS/Medicare


Jurisdiction and Exclusive Remedy

  1. 2nd DCA Unpublished - Maraj v Ralphs Grocery
    • Prankster raises shopping cart up on Ralphs Grocery flag pole. Worker seriously hurt trying to put flag up in morning. Store manger told Emergency team she did not know what happened, but called hospital later that day when she found out. Worker sues claiming fraudulent concealment (i.e. Johns-Manville exception).
    • Held: No evidence LC 3602, subdivision (b)(2) narrow exception to excusive remedy applies.
  2. Published opinion of Edward Carey Construction Company v State Compensation Insurance Fund. (March 2011)
    • Injured worker was owner of the company. When employer notified SCIF of the injury, SCIF asserted the policy "had been canceled and was not in effect." Employer obtained a ruling through binding arbitration that its insurance policy with SCIF was in full force and effect at the time of injury. Sued SCIF in Superior Court for breach of contract and breach of the implied covenant of good faith and fair dealing.
    • HELD: Case was appropriate and dismissal overturned.
    • Cal. Ct. App. Mar. 25, 2011
  3. LeFiell Manufacturing Company v The Superior Court of Los Angeles County, Published Court of Appeal (March 2011)
    • Claim that injury was caused by employers "knowing and intentional removal of, or knowing and intentional failure to install a point of operation guard" on the swaging machine which is a power press. Injured worker's spouse seeks damages for loss of consortium.
    • Section 4558 (Power Press Exception) is one of the four statutory exceptions to the exclusive remedy rule. Court of Appeal Approves Loss of Consortium Expansion of Power Press Exception to allow spouse to claim damages.
    • Supreme Court has granted a petition for review.
    • 193 Cal.App.4th 1413
  4. Donnell Gilbreath v Holland Residential LLC, 2nd DCA Unpublished (December 2010)
    • Condo manager trips and falls while walking her dog and "inspecting property" and carrier denies AOE-COE. Manger then sues employer for premises liability claiming that exclusive remedy should not apply since carrier denied she was in course of employment
    • HELD: The insurer's denial of the claim does not constitute evidence that she was acting outside the course and scope of her employment.
    • 75 Cal. Comp. Cases 1359
  5. 2nd DCA Unpublished, Terry Bazzini v Technicolor Inc., (January 2010)
    • Technicolor employee sued in Superior Court claiming they fraudulently concealed his chemical exposure triggering L.C. 3602(b)(2) exception to exclusive remedy. Summary judgment entered in favor of Technicolor. (i.e. Johns-Manville exception)
    • HELD: Employee had no evidence that Technicolor knew his dermatitis was a symptom of chemical poisoning that could lead to cancer. Worker cannot "merely speculate" that Technicolor knew.
    • 74 Cal.Comp.Cases 16