Abdala v. Aziz

In Abdala v. Aziz (1992) 3 Cal. App. 4th 369, employee Abdala sustained an industrial back injury. The workers' compensation carrier became obligated to provide medical and other benefits to Abdala. Weeks after the industrial injury, Abdala was injured in an automobile accident which aggravated her back injury. The carrier was obligated to pay the additional medical bills resulting from the automobile accident. The court reasoned that, "section 3852 et seq. must be interpreted to allow employers subrogation rights whenever, and to whatever extent, an employee suffers a subsequent tortious injury which also increases the employer's liability for compensation. This is true whether or not that subsequent injury is industrial in nature." ( Abdala v. Aziz, supra, 3 Cal. App. 4th at p. 375.)