BENJAMIN MARTINEZ vs. SPRINGER TERMITE & PEST, INC., CALIFORNIA INSURANCE COMPANY, APPLIED RISK SERVICES, INC.

The Appeals Board granted reconsideration for lien claimants California Pharmacy Management and Long Beach Prescription Pharmacy, rescinding the administrative law judge's disallowance of their liens. The Board found that while lien claimants bear the burden of proving licensure, they were not afforded a full and fair opportunity to do so when the judge raised the issue for the first time at trial. The case is remanded to the trial level for further proceedings and a decision after the record regarding licensure is fully developed.