Rosa Reyes vs. Nestle USA, ACE American Insurance

This case involved lien claimants whose liens were disallowed because their Labor Code section 4903.8(d) declarations were signed with electronic "S" signatures rather than wet signatures. The Workers' Compensation Appeals Board (WCAB) granted reconsideration, holding that electronic signatures are valid for these declarations. The WCAB found that existing law and prior panel decisions support the use of electronic signatures, aligning with the Uniform Electronic Transactions Act. The matter was returned to the trial level for further proceedings consistent with this ruling.