Rangel: Authorized Electronic Payments Satisfied a Disputed Settlement

If you are waiting for a workers’ compensation settlement, an electronic “paid” notice offers little comfort when you cannot find the money. The first task is to trace the payment and the instructions used to send it. A dispute can turn on who selected the destination, what changed and whether the records support the claim of nonreceipt.

In Rangel v. Main Electric Supply Co., No. ADJ17873629 (WCAB Jan. 21, 2025), a worker sought another payment of his settlement after the insurer sent the money through Zelle. The Workers’ Compensation Appeals Board upheld the finding that the insurer had paid him. Written authorization, the payment history and contradictions in his testimony supported that result.

The dispute concerned $21,250 in settlement payments

Omar Rangel injured his right shoulder and thoracic spine while working for Main Electric Supply Company on May 16, 2023. He settled the claim through a Compromise and Release signed on April 3, 2024, and approved the next day. The $25,000 settlement, less $3,750 in attorney fees, left $21,250 payable to him.

Travelers’ records identified two settlement payments of $15,067.50 and $6,182.50, totaling that net amount. Rangel contended that the insurer had paid someone else and that he had not received his money. The resulting trial addressed whether Travelers had to reissue payment and, if so, whether penalties, sanctions and interest should follow.

The payment history in Rangel explains why the administrator’s records needed to be examined alongside the worker’s account. The question was whether the settlement obligation had been satisfied through the payment arrangement he selected.

The payment authorization connected the account to the claim

The worker had enrolled in electronic benefit payments through the MyTravelers portal. The insurer’s unit manager described a process involving a signed disclaimer, an email address or phone number associated with the Zelle account and a password. The portal also kept a history of changes to payment preferences.

Rangel initially used one phone number, then changed the payment destination on May 31, 2023. The replacement number belonged to a coworker. He acknowledged providing an account under the coworker’s name even though the payments were to be issued in his own name. Earlier temporary disability payments sent through that arrangement had been received and confirmed.

The transaction and account evidence in Rangel identified both settlement payments in his name at the destination associated with that replacement number. The insurer therefore supplied more than a general statement that it had pressed “send”: Its witness explained the enrollment process, and its records connected the selected destination to the payments.

Labor Code section 4651(a)(2) permits disability indemnity deposits into an account at a bank, savings and loan association or credit union of the employee’s choice in California when the employee voluntarily authorizes them. It also permits electronic deposits into an account previously authorized for payroll unless the employee requests in writing that disability indemnity not be deposited there.

Applying that provision, the authorization analysis in Rangel found that the insurer used the account the worker voluntarily selected in this state. He had not requested in writing that payments stop going into that account. The authorization and absence of a written change mattered because he was asking the insurer to pay the same settlement again.

The worker’s account of the arrangement conflicted with earlier records

At trial, Rangel said he did not know the coworker’s last name, was no longer in touch with her and had known her for only a short time. His employment application identified her as a reference he had known for more than 32 years. The application also listed an email address containing her surname. He did not remember listing her as a reference.

The judge found the insurer’s witness credible and Rangel’s testimony inconsistent. Those were specific conflicts in the evidence about the relationship and payment arrangement. Describing them accurately matters more than attaching a label such as fraud to the dispute.

On reconsideration, the Board gave the judge’s credibility findings great weight because the judge had observed the witnesses. It applied Garza v. Workmen’s Compensation Appeals Board, 3 Cal.3d 312, 318–319 (1970), and found no evidence of considerable substantiality warranting rejection of those findings. The credibility discussion in Rangel connects that standard to the actual contradictory records.

For a worker disputing receipt, this makes preparation important. Review earlier authorizations, messages and applications before giving testimony. If a record appears wrong or circumstances changed, identify the record, explain the discrepancy and preserve the evidence supporting the explanation. Guessing about an old arrangement can obscure the payment question that needs to be resolved.

The Board left the payment finding in place

The Board concluded that Travelers had complied with section 4651 and rendered payment under the authorized arrangement. It therefore owed no additional settlement payment. The formal order in Rangel denied reconsideration of the November 1, 2024 findings and order, leaving the determination that $21,250 had been paid in place.

The record combined a voluntary electronic-payment election, the change log, earlier payments received through the same arrangement, identifiable settlement transactions and credibility findings. Each addressed a different part of the worker’s contention that payment had gone to someone else. The result followed that combined proof.

Preserve both the instructions and the payment trail

If a settlement payment is missing, obtain the approved agreement and compare the gross amount, attorney fee and net amount with the administrator’s ledger. Ask for the transaction details, payment destination used, completion or return status and the authorization relied on. Keep your own bank records and any payment-preference changes alongside that response.

If the destination is no longer one you can access, tell the administrator promptly in writing and preserve its response. Keep a copy of any instruction changing or ending electronic deposits. Confirm how the administrator will handle future payments and ask what happened to the specific transfer already in dispute. A future preference change and a completed transfer need separate follow-up.

Give account details and supporting records to counsel or the administrator through an appropriate secure channel. Our public consultation form asks for a brief description of the problem; it is not the place for bank numbers, passwords or another person’s private contact information.

Our returned-settlement-check guide addresses a different delivery problem involving mailed payment and replacement correspondence. Rangel concerns the worker’s electronic-payment election and the evidence connecting it to completed transfers. Bring the actual instructions, change history, transaction records and your explanation of nonreceipt so the review can focus on where the money went and what remains unpaid.