“[N]o release of liability or compromise agreement is valid unless it is approved by the appeals board or referee.”
(Lab. Code, § 5001, as quoted in Gaines, supra, at p. 17.)
“A tort release is effective upon execution, but a compromise and release of workmen’s compensation liability is invalid until approved… This inquiry by the referee should carry out the legislative objective of ‘protecting workmen who might agree to unfortunate compromises because of economic pressure or lack of competent advice.’ … These safeguards against improvident releases place a workmen’s compensation release upon a higher plane than a private contractual release; it is a judgment, with ‘the same force and effect as an award made after a full hearing.’”
(Johnson v. Workmen’s Comp. Appeals Bd. (1970) 2 Cal.3d 964, 973, quoting Chavez v. Industrial Acc. Com. (1958) 49 Cal.2d 701, 702, and Raischell & Cottrell, Inc. v. Workmen’s Comp. App. Bd. (1967) 249 Cal.App.2d 991, 997; as quoted in Gaines, supra, at p. 17; accord Camacho v. Target (2018) 24 Cal.App.5th 291, 301–302 [as cited therein].)
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