Workers’ Compensation · Primary-source case analysis

Karaiskos: EDD Benefit Liens Could Be Covered Claims Payable by CIGA

By Aneeta Mishra and Timothy Chan

Published September 13, 2026

Karaiskos and its companion matter addressed CIGA responsibility for EDD liens after a compensation insurer’s insolvency.

EDD had paid benefits during the disputed period

The agency asserted statutory liens for disability benefits paid to injured workers while compensation liability remained unresolved.

CIGA relied on the state-obligation exclusion

It argued that reimbursing a state agency was outside the statutory definition of covered claims.

The liens derived from the workers’ claims

The Board concluded the reimbursement rights were tied to benefits paid on behalf of the injured workers rather than an independent state obligation.

The matters were returned for further proceedings

The WCAB held that CIGA could be liable and remanded for case-specific findings and payment issues.

Key takeaways

• Identify the benefit period covered by each lien.
• Trace the lien to the worker’s compensation entitlement.
• Document insurer insolvency and CIGA’s claim assumption.
• Separate covered-claim status from the amount and validity of the lien.