Adding more confusion to mix on apportionment, the First District Court of Appeal rules in a decision issued yesterday, that apportionment of permanent disability is calculated by subtracting dollars, not percentages. The case, John Shevchuk v. Workers' Compensation Appeals Board and United Airline, is unpublished, which means it cannot be cited to either the appellate or supreme court, but adds to the drama. Another apportionment case, Welcher v. Workers' Compensation Appeals Board, Hat Creek Construction, Inc., is before the California Supreme Court.
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