New And Further Disability
New and further disability is not defined in the statutes and judicial interpretation has not flushed out all its potential permutations. Thus, its meaning is not entirely clear. However, it has been judicially defined “to mean disability . . . resulting from some demonstrable change in an employee’ condition, including a gradual increase in disability. .” Nicky Blair’s Restaurant v. WCAB (1980) 45 CCC 876. See CHP v WCAB (2010) 75 CCC 1241.