Christian v. Workers' Comp. Appeals Bd

In Christian v. Workers' Comp. Appeals Bd. (1997) 15 Cal. 4th 505, 511 63 Cal. Rptr. 2d 336, 936 P.2d 115, our Supreme Court clarified the rule: "While we have held that multiple penalties must be applied in some circumstances, those penalties have been approved only when the refusal of, or delay in payment of benefits, necessarily involved separate and distinct unreasonable acts by the insurance carrier. Those multiple penalties involved separate classes of benefits, individual claims for payment or reimbursement of medical or travel expenses, or a repeated refusal or delay in payment of a benefit after the same conduct had already been found by the Board to be unreasonable and a prior penalty imposed, or some analogous, legally significant event such as a stipulation of liability by the carrier had intervened between the first act for which a penalty was imposed and the second."