TRACY HOVLAND vs. DISPENSING DYNAMICS INTERNATIONAL, STAFFING NETWORK LLC, AEROTEK, ALLEGIS GROUP, INC., EMPLOYCO USA, THE HARTFORD SYRACUSE, ESIS CHATSWORTH, LUMBERMEN'S UNDERWRITING BOA RATON, SEDGWICK CIGA GLENDALE, REPUBLIC INDEMNITY ENCINO, AMTRUST CONCORD, California Insurance Guarantee Association (CIGA)

The Workers' Compensation Appeals Board rescinded prior orders denying reimbursement for CIGA and dismissal for Hartford. The WCAB clarified that CIGA, unlike other insurers, is entitled to reimbursement rather than just contribution from solvent insurers when handling claims due to insurer insolvency. The Board also found Hartford's dismissal petition premature, as the underlying workers' compensation claim still requires adjudication. The case is returned to the trial level for further proceedings to resolve the underlying claim and related indemnity issues.