January 14, 2026
Court of Appeal, Sixth Appellate District
The Rule of Zenith Insurance Company v. Workers' Compensation Appeals Board is that equitable tolling of the 60-day deadline under former Labor Code section 5909 cannot justify the Workers' Compensation Appeals Board's 20-month delay in issuing a decision on reconsideration after granting a petition for "further study," under circumstances where the Board failed to demonstrate reasonable and good faith conduct in attempting to comply with statutory procedures.