Authorities as the decision cited them, with how this panel applied each one.
Lab. Code, § 5803.1
The appeals board has continuing jurisdiction and may rescind, alter, or amend any order, decision, or award for good cause upon notice and opportunity to be heard (Lab. Code, § 5803.1).
Applied to determine whether Petition for Reconsideration should be granted or dismissed.
From the decision · page 3"The appeals board has continuing jurisdiction over all its orders, decisions, and awards
made and entered under the provisions of [Division 4]... At any time, upon notice and after the
opportunity to be heard is given to the parties in interest, the appeals board may rescind, alter, or
amend any order, decision, or award, good cause appearing therefor." (Lab. Code, § 5803.1)
Civ. Code, §§ 1550, 1565, 1580
Contract principles apply to workers' compensation settlements; mutual agreement and meeting of the minds are required (Civ. Code, §§ 1550, 1565, 1580).
Applied to interpret stipulations with request for award and assess mutual mistake claim.
From the decision · page 3We observe that contract principles apply to settlements of workers' compensation
disputes. The legal principles governing compromise and release agreements, and by extension,
stipulations with request for award, are the same as those governing other contracts. (Burbank
Studios v. Workers' Co. Appeals Bd. (Yount) (1982) 134 Cal.App.3d 929, 935.) There can be no
contract unless there is a meeting of the minds and the parties mutually agree upon the same thing.
(Civ. Code, § 1550, 1565, 1580; Sackett v. Starr (1949) 95 Cal.App.2d 128; Sieck v. Hall (1934)
139 Cal.App. 279, 291; American Can Co. v. Agricultural Ins. Co. (1909) 12 Cal.App. 133, 137.)
Johnson v. Workmen's Comp. Appeals Bd. (1970) 2 Cal.3d 964
Good cause to set aside settlement includes mutual mistake, duress, fraud, undue influence, and procedural irregularities (Johnson v. Workmen's Comp. Appeals Bd. (1970) 2 Cal.3d 964).
Applied to evaluate whether good cause exists to rescind stipulations and awards.
From the decision · page 4A stipulation is "`An agreement between opposing counsel... ordinarily entered into for
the purpose of avoiding delay, trouble, or expense in the conduct of the action,' (Ballentine, Law
Dict. (1930) p. 1235, col. 2) and serves `to obviate need for proof or to narrow range of litigable
issues' (Black's Law Dict. (6th ed. 1990) p. 1415, col. 1) in a legal proceeding." (County of
Sacramento v. Workers' Comp. Appeals Bd. (Weatherall) (2000) 77 Cal.App.4th 1114, 1118 [65
Cal.Comp.Cases 1].) Stipulations are binding on the parties. (Id., at 1121.) However, if there is a
showing of good cause, the parties may be permitted to withdraw from their stipulations. (Id.)
Whether "good cause" exists to set aside a settlement depends upon the facts and circumstances
of each case. "Good cause" includes mutual mistake of fact, duress, fraud, undue influence, and
procedural irregularities. (Johnson v. Workmen's Comp. Appeals Bd. (1970) 2 Cal.3d 964, 975 [35
Cal.Comp.Cases 362]; Santa Maria Bonita School District v. Workers' Comp.