60.4.17 Permanent Partial Disability against Permanent Total Disability

Inasmuch as permanent partial disability is a different benefit than permanent total disability, a defendant is not entitled to a credit of earlier permanent partial disability against a subsequent award of permanent total disability following a formal Petition to Reopen by an applicant. Such was the case in City of San Buenaventura, et al., v. W.C.A.B. (Schulte) (2006) 71 Cal.Comp.Cases 823 (Writ Denied), where defendant was found not entitled to credit a prior stipulated permanent partial disability award of 30½ percent permanent disability against a subsequent total permanent disability award (100 percent) following her successful Petition to Reopen because permanent partial disability and permanent total disability are distinctly different benefits and the applicant was held to be entitled to the full benefit of each award.