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At the Lectern

Supreme Court finds certain workers’ compensation benefits are limited to volunteer peace officers

October 26, 2015

In Larkin v. Workers’ Compensation Appeals Board, the Supreme Court today concludes that certain workers’ compensation benefits for volunteer police officers are not also available to regularly sworn, salaried officers.

The unanimous opinion by Justice Mariano-Florentino Cuéllar digs deep into the statutory construction toolbox, looking at “the text” of two statutes, “their place in the structure of the statutory scheme,” “the Workers’ Compensation Appeals Board’s . . . interpretation of the statute,” and “the legislative history governing the relevant statutory provisions” (including, uncommonly, an individual legislator’s letter to the Governor).

The opinion affirms the Third District Court of Appeal.

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