MELVIN BEACHAM vs. CENTURY PARKING, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION, INTERCARE INSURANCE SERVICES, HIH AMERICA

The Workers' Compensation Appeals Board denied lien claimant Elena Konstat, Ph.D.'s petition for reconsideration. The WCJ correctly found that Konstat failed to prove applicant Melvin Beacham sustained an industrial psychiatric injury. Furthermore, the Board found no basis for estoppel against the defendant, as they consistently denied liability for the psychological claim and relied on Dr. Nehamen's reports finding no industrial psychiatric injury. Therefore, Konstat is not entitled to recover her outstanding lien claim.