In Safway Steel Etc. Co. v. Ind. Acc. Com. (1942) 55 Cal. App. 2d 388, the board awarded Alyce Helmick benefits for the wrongful death of her husband. Safway Steel Scaffold Co. was found guilty of serious and willful misconduct, which was not covered by the company's insurance. Helmick enforced the judgment against Safway and was awarded $ 654.78. Upon rehearing, the board revoked the finding of serious and willful misconduct. Safway filed a lien for the $ 654.78 against the remainder of the workers' compensation benefits awarded Helmick. The board permitted the lien, reasoning the monies paid were equivalent to living expenses for which a lien may be allowed pursuant to Labor Code section 4903, subdivision (c). Labor Code section 4903 lists permitted lien claims. Subdivision (c) provides a lien may be filed for "the reasonable value of the living expenses of an injured employee or of his or her dependents, subsequent to the injury." The Safway court reasoned that compensation paid to an injured worker under the mistaken belief the worker was entitled to such payments was the equivalent of furnishing the injured worker with living expense advances. By allowing a lien against unpaid compensation, the Safway court effectively allowed a credit against future compensation whatever the species. (Safway Steel etc. Co. v. Ind. Acc. Com., supra, 55 Cal. App. 2d at pp. 388-389.)