Paul Neyer — ADJ3180323, ADJ1492342, ADJ4336300, ADJ3602025

Applicant Paul Neyer resolved four claims (two specific injuries while Mission Linen was self-insured, a motor vehicle accident, and a cumulative trauma covered partly by insolvent Credit General/CIGA and partly by Arrowpoint) through Compromise and Release. Arrowpoint subsequently settled CIGA's contribution claim for $225,000 and sought reimbursement of $41,653 from Mission Linen. The arbitrator ordered Mission Linen to reimburse Arrowpoint for sums paid in excess of Arrowpoint's pro rata share of liability without explaining the basis. The Appeals Board, after reconsideration, held that pro rata division is appropriate for cumulative trauma among jointly liable insurers but not for successive distinct injuries, and that Arrowpoint, as an insurer, cannot claim the same 'other insurance' reimbursement rights CIGA would have had. The Board rescinded the Findings and Order and remanded to the arbitrator to apply the correct legal principles.