Twenty-four separate injured workers submitted Compromise & Release agreements for approval at the Van Nuys district office and got, instead, orders suspending action — demanding supporting medical evidence, more discovery, and in places dismissal of the claim with prejudice. On June 24, 2026 the Appeals Board took all of them up at once, en banc (Gaines v. ABM Aviation, Inc., 2026-EB-01) — making the result binding precedent on every WCJ in the state.
First: a workers’ compensation settlement “is only enforceable after approval by the Workers’ Compensation Appeals Board,” and in approving one the judge must consider whether it is valid and must determine whether it is adequate “to protect the injured worker and the public interest.” Second: where the terms are inconsistent, non-compliant, or inadequate, the judge may investigate — an order suspending action, and if the parties don’t supply enough, a hearing to build an evidentiary record on adequacy.
So adequacy review is real, and it has teeth. What it is not, the Board explains, is a license to relitigate the case: the inquiry “should be limited in scope to address the issue of adequacy,” and it should happen on the record. Civil-lawsuit information can be requested only where a third-party credit could bear on adequacy; dismissal with prejudice is for merits dispositions, not leverage; and the WCAB approves only Labor Code benefits — a settlement of anything outside the Labor Code isn’t enforceable there at all. Attorney-fee documentation, by contrast, is squarely fair game: no fee agreement is enforceable “in excess of a reasonable amount,” and the Board is the final arbiter of reasonableness (§4906(a), Rule 10844).
The Board rescinded every one of the orders — and disqualified the judge from all twenty-four cases under §5311 and Code of Civil Procedure §641(f)–(g), quoting reports that called the system a “free cash money handout system” among other expressed opinions the Board found “clearly warrant disqualification.” Each case goes back to the presiding judge for reassignment.
The practical shape of the decision: a C&R that arrives with consistent terms, medical evidence supporting the number, and a documented fee request gives an adequacy reviewer nothing to suspend. The number itself is checkable arithmetic — the settlement calculator prices the rating the parties are settling around, the commutation calculator shows the present-value math behind lump sums and fees, and the structural choice is the C&R-vs-Stips decision. Descriptive summary of a public decision; not legal advice.
Plain-language summary for informational use; not legal advice. Figures are quoted from the cited sources.