Gregg Hamilt — ADJ805478, ADJ1289904, ADJ2355545

Applicant Gregg Hamilt sustained three separate injuries (one specific 1983 injury and two cumulative trauma injuries) while working for the same employer, each insured by a different carrier (Travelers, Wausau/Liberty Mutual, and Arrowood/Royal Sun Alliance). After a 2015 trial, the WCJ issued three separate Findings and Awards with Benson apportionment of one-third to each injury and joint and several liability for future medical care. Travelers and Wausau later settled their respective claims by Compromise and Release including future medical, but Arrowood did not settle and became the sole administrator of future medical treatment. Arrowood sought contribution/reimbursement from Travelers and Wausau for benefits paid both before and after the C&R approvals. The Arbitrator found Arrowood entitled to one-third contribution from each carrier only for benefits paid before the C&R approval dates, but barred any contribution for amounts paid afterward, reasoning Arrowood should have asserted credit or pro-rata (one-third) liability rather than paying 100% of future medical. The WCAB granted reconsideration to study the issues and then affirmed the Arbitrator's February 7, 2022 Findings and Award.