SEAN HANSEN, LISA LAWSON, TIMOTHY GILBERT, CARLOS GONZALEZ vs. CITY OF LOS ANGELES

The Workers' Compensation Appeals Board (WCAB) granted reconsideration and returned multiple lien claims against the City of Los Angeles to the trial level. The WCAB found that the Workers' Compensation Judge (WCJ) erred by applying collateral estoppel based on a prior decision in Halaby v. City of Los Angeles. The WCAB clarified that the doctrine of laches is fact-specific and a prior finding of laches does not preclude relitigation of the issue in new cases. Therefore, the defendant must prove the elements of laches independently for each current lien claim.