Maria Andrade — ADJ11377591

Applicant Maria Andrade, a flight attendant, sustained industrial injuries to her right shoulder and right foot/ankle on November 30, 2014, and her claim resolved via Stipulations for 69% permanent disability, which was fully paid. The parties subsequently negotiated a Compromise and Release (primarily to fund a CMS-approved MSA for future medical care), and the applicant signed it on February 18, 2022, with counsel returning it on February 19 and defense submitting it electronically on February 23, 2022. Unknown to all parties, the applicant had died on February 21, 2022, before the C&R was approved by the Board. The WCJ found the C&R unenforceable and issued a take-nothing order, reasoning that the applicant's death constituted a material change in circumstances and that liability for future medical care ceased upon death. The WCAB denied reconsideration, adopting and incorporating the WCJ's report.