Kerley v. Workmen's Comp. App. Bd

In Kerley v. Workmen's Comp. App. Bd. (1971) 4 Cal.3d 223, the court said: "In summary, we hold that the only satisfactory excuse for delay in payment of disability benefits, whether prior to or subsequent to an award, is genuine doubt from a medical or legal standpoint as to liability for benefits, and that the burden is on the employer or his carrier to present substantial evidence on which a finding of such doubt may be based."