Raphael v. Bloomfield

After the Employment Development Department (the EDD) paid temporary unemployment compensation disability (UCD) benefits to a disabled worker, it filed a lien claim for reimbursement from the employers insolvent workers compensation carrier. California Insurance Guarantee Association (CIGA) assumed the insolvent carriers obligations, but refused to satisfy the EDDs lien. CIGA argued it is only required to pay a "covered claim" and the EDDs lien is an obligation to a state that is excluded from the definition of "covered claims." (Ins. Code, § 1063.1, subd. (c)(4).) The Workers Compensation Appeals Board (the Board) ruled against CIGA, reasoning that reimbursement of the EDDs lien is a payment to the particular disabled workers account, not to the EDD.