The court shall, upon further application at any time before the judgment is satisfied, allow as a further lien the amount of any expenditures of the employer for compensation subsequent to the original order.
Cal. Lab. Code § 3857
Subrogation of Employer
Applied in 4 court decisions — leading case 12 Cal. 3d 884 - Roe v. Workmen's Compensation Appeals Board (1974)
Most recently applied in 12 Cal. 3d 884 - Roe v. Workmen's Compensation Appeals Board (November 1974)
Enacted by Stats. 1937, Ch. 90.
How often courts cite this section
Court decisions citing this, by year. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
Official source: California Legislative Information. Reproduced from public-domain California statutes; confirm against the official source for the current text. Not legal advice.