Corrine Shatzer, vs. Qualex, Inc.; Old Republic Insurance,
(SAC 0317143) is a case in which defendant Qualex, Inc. and Old Republic Insurance sought reconsideration of an earlier decision by the Workers’ Compensation Appeals Board. The decision reversed the apportionment of applicant Corrine Shatzer’s permanent disability because it was not supported by substantial medical evidence and amended the award of applicant’s attorney’s fees and rescinded the order disallowing Sutter’s lien. The defendant argued that instead of reversing the finding of apportionment, the Board should have rescinded the finding of permanent disability and returned the case to the trial level for development of the record on the issue of apportionment. The Board denied reconsideration because the defendant had notice before trial that the issue of app