Chester Taylor worked as a kosher food manager/inmate laborer for State of California, Department of Corrections Inmate Claims when he sustained an industrial injury to his bilateral arms on January 20, 2017.
The injury was resolved through a Stipulated Findings & Award on April 6, 2024, which provided him with a 76% permanent disability rating. The defendant, State Compensation Insurance Fund (SCIF), paid permanent disability benefits at a weekly rate of $160.00, totaling $49,406.39 through December 13, 2024.
Mr. Taylor filed a petition to commute his remaining permanent disability benefits into a lump sum, covering the period from December 13, 2024, for the remainder of his life expectancy.
At trial, he testified that his monthly income (from Social Security, workers’ compensation, and SNAP benefits) totaled $2,428.00, while his expenses (rent, food, medical copays, and dental expenses) amounted to $1,251.00. He claimed to be in arrears by $300.00 to $600.00 per month, borrowing approximately $600.00 per week from his daughter. However, he provided no documentary evidence to substantiate these figures.
The presiding Workers’ Compensation Administrative Law Judge (PWCJ) denied Mr. Taylor’s petition, finding that he failed to meet the burden of proof under Labor Code § 5100(a). The lack of documentary evidence supporting his financial claims and the unclear calculations of his expenses were critical factors.
The WCAB denied reconsideration in the panel decision of Chester Taylor vs. State of California, Department of Corrections Inmate Claims – ADJ13319691 (April 2025).
Under Labor Code § 5100(a), commutation of benefits is allowed if it is “necessary for the protection of the person entitled thereto, or for the best interest of the applicant.” Additionally, § 5100(b) requires that commutation must avoid inequity and not cause undue expense or hardship to the applicant.
The Workers’ Compensation Appeals Board (WCAB) has discretion to grant or deny commutation, and the applicant bears the burden of proving the necessity of commutation. (Hulse v. Workers’ Comp. Appeals Bd. (1976) 63 Cal.App.3d 221, 226 [41 Cal.Comp.Cases 691].)
The PWCJ also noted that commuting the benefits could potentially cause undue hardship, as Mr. Taylor’s current income, including permanent disability payments, was insufficient to cover his expenses. Commuting the benefits would reduce or eliminate this income stream, potentially exacerbating his financial difficulties.
The WCAB, in its Opinion and Order dated April 8, 2025, adopted and incorporated the PWCJ’s report and denied the Petition for Reconsideration, affirming the PWCJ’sdenial of commutation.
The WCAB noted that Mr. Taylor remains free to file a new petition for commutation if he can provide adequate evidence meeting the requirements of Labor Code § 5100(a) and (b).