In State Compensation Ins. Fund v. Workmen's Comp. App. Bd. (Childs) (1970) 8 Cal.App.3d 978, the petitioner was injured while working as a member of a road gang while an inmate of the Los Angeles County jail. ( Id., at p. 979.) Petitioner had worked daily on various projects and was paid approximately 50 cents per day for his labor. There was no indication that his sentence was reduced because of his work. He testified he had volunteered to work on the highway job, and he was not required to do so. (Ibid.) The only evidence showing the petitioner was a volunteer was his own testimony he had volunteered for the job. The court noted, however, that under Penal Code section 4017 the county board of supervisors could have adopted an ordinance requiring prisoners to perform labor, but such an ordinance had never been enacted in Los Angeles County. ( Id., at pp. 981-982.) The Childs court held petitioner's work was voluntary; he performed a service in return for the gratuity of 50 cents a day. Therefore, he was an employee eligible for workers' compensation. ( Id., at p. 983.) The court cited the policy of liberal construction of California's workers' compensation laws and further noted the policy of stressing rehabilitation of those convicted of crimes. The court declared that precluding coverage under workers' compensation for voluntary labor performed by prisoners would be a disincentive for them to participate in such activity. (Ibid.)