C&R Unsigned Before Claimant's Death Cannot Be Approved

S. M. Facchine, et al. v. WCAB (Pure Carbon Co. & PMA Group) held that because the statute requires the Compromise and Release be signed and notarized or witnessed, an Agreement could not be approved when the Claimant passed away before signing. The Court stated the plain language of the statute could not be disregarded with the pretext of pursuing its spirit.