Human Engineering Laboratory v. Workers' Compensation Appeals Board

Petitioner Human Engineering Laboratory (Laboratory) seeks review of contribution proceedings brought against it before *341 respondent Workers’ Compensation Appeals Board (Board) by respondent State Compensation Insurance Fund (State Fund). State Fund successfully obtained contribution from Laboratory regarding a workers’ compensation claim brought by one of Laboratory’s employees, Joseph P. Wallace, against Laboratory. Wallace obtained an award against State Fund, one of Laboratory’s workers’ compensation insurance carriers. State Fund then sought contribution from Laboratory’s other carriers during the period of Wallace’s injurious employment ex-, posure at Laboratory. Laboratory was unable to discover who some of its compensation carriers were; the Board allowed State Fund to obtain contribution directly from Laboratory.

Laboratory challenges the Board’s decision to allow State Fund to obtain contribution directly from Laboratory on the grounds: (1) the Labor Code does not permit State Fund to seek contribution directly from Laboratory; (2) substantial evidence does not support the finding that Wallace’s employment during the period for which Laboratory’s insurance…