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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. ADJ9542328
En Banc
Nov 14, 2019

ASHLEY COLAMONICO vs. SECURE TRANSPORTATION, NATIONAL UNION FIRE INSURANCE COMPANY

The Appeals Board held that a medical-legal provider has the initial burden to prove an expense was for a contested claim and was reasonable and necessary per Labor Code §§ 4620-4621, and a defendant does not waive these objections by failing to raise them in an Explanation of Review (EOR) under § 4622.

Med-Legal PhotocopyEn Banc DecisionPetition for ReconsiderationFindings and OrdersLien ClaimantExplanation of ReviewContested ClaimReasonable and Necessary ExpensesBurden of ProofLabor Code Section 4620
References
11
Case No. ADJ9271102
Regular
Oct 18, 2018

CELIFLORA LOPEZ vs. HARBOR VIEW FARMS, LLC, ZENITH INSURANCE COMPANY

The Workers' Compensation Appeals Board granted reconsideration, finding the lien claimant failed to prove its services constituted valid medical-legal expenses. The defendant successfully argued that the claim was not "contested" under Labor Code § 4620(b) at the time the copy services were rendered. Therefore, the lien claimant is barred from recovery for these expenses.

Workers' Compensation Appeals BoardLabor Code Section 4620Medical-Legal ExpensesContested ClaimLien ClaimantPetition for ReconsiderationFindings of FactRescindedWestern Imaging ServicesZenith Insurance Company
References
4
Case No. ANA 0391266
Regular
May 27, 2008

ENRIQUE CASTELLANOS vs. PREFERRED FRAMING, ARGONAUT INSURANCE COMPANY

This case involved a lien claimant seeking full reimbursement for subpoena service charges, which the WCJ only allowed in the amount of $73.91. The lien claimant failed to meet their burden of proof to demonstrate that these charges were reasonable and necessary for proving a contested claim under Labor Code § 4620. Consequently, the Workers' Compensation Appeals Board denied the petition for reconsideration.

Associated Reproductive ServicesInc.Petition for ReconsiderationFindings of Fact and OrderCompromise and Releaseindustrial injuryheadachesblurred visionlien claimantburden of proof
References
2
Case No. LAO 0816137
Regular
Aug 08, 2008

LUCIOUS HUGHES vs. KAISER FOUNDATION HOSPITAL, KAISER PERMANENTE CARE PROGRAM

The Workers' Compensation Appeals Board granted reconsideration and rescinded a prior award, ruling that two doctors' lien claims for medical-legal expenses were not valid. The Board found that these expenses were incurred before a disputed claim existed, as defined by Labor Code section 4620, and therefore were not reasonable or necessary litigation costs. Consequently, both Dr. Gromis and Dr. Bloch were ordered to take nothing on their respective lien claims.

Medical-legal liensdisputed claimcontested claimLabor Code section 4620Labor Code section 4621Beverly Hills Multi Specialty Medical Group v. Workers' Comp. Appeals Bd.Del Rio v. Quality Hardware Incorporatedlien enforcementtreating physicianprimary treating physician
References
2
Case No. ADJ9542328
Regular
Nov 14, 2019

ASHLEY COLAMONICO vs. SECURE TRANSPORTATION, NATIONAL UNION FIRE INSURANCE COMPANY, SEDGWICK CMS

This en banc decision clarifies that medical-legal providers, not defendants, bear the initial burden of proving their services were reasonable and necessary pursuant to Labor Code section 4621. Defendants do not waive objections based on sections 4620 or 4621 by failing to raise them in an Explanation of Review. The Appeals Board rescinded the WCJ's findings and remanded the case for further proceedings on the provider's burden of proof. This precedent applies to all future Appeals Board decisions.

Med-Legal PhotocopyExplanation of Review (EOR)Contested ClaimBurden of ProofReasonable and Necessary ExpensesLien ClaimantWaiver of ObjectionsSection 4620Section 4621Section 4622
References
13
Case No. ADJ6969503
Regular
Apr 15, 2019

MARIA RODRIGUEZ vs. CHILDREN'S HOME OF SOUTHERN CALIFORNIA, EVEREST NATIONAL INSURANCE COMPANY, GALLAGHER BASSETT SERVICES

The Workers' Compensation Appeals Board granted reconsideration to review an administrative law judge's decision regarding a lien claimant's bill. The Board affirmed payment for medical treatment but disallowed reimbursement for a medical-legal psychological evaluation. This was because no psychiatric claim was contested at the time the evaluation was performed, failing to meet the statutory requirement of Labor Code sections 4620 and 4621. The Board rejected the argument that the employer waived this requirement by not timely objecting.

Workers' Compensation Appeals BoardLien ClaimantMedical-Legal EvaluationContested ClaimLabor Code Section 4620Labor Code Section 4621Petition for ReconsiderationAmended Findings and OrderPsychiatric InjuryBurden of Proof
References
2
Case No. ADJ9835514
Regular
Nov 07, 2017

CARLO MAGNO vs. AMERICAN SOLAR DIRECT, INC., CYPRESS INSURANCE COMPANY

This case concerns a lien claimant, Med-Legal Photocopy, seeking reimbursement for costs incurred in obtaining medical records. The Workers' Compensation Appeals Board denied the lien claimant's petition for reconsideration. The Board found the claimant failed to meet its burden of proof to establish that the expenses were incurred for a "contested claim" as required by Labor Code section 4620. Therefore, the defendant is not liable for the lien claimant's expenses related to obtaining these records.

Med-Legal PhotocopyPetition for ReconsiderationFindings and AwardEDEXSCPMG/KFHGreen River Family DentistryRancho Physical TherapyBerkshire HathawayAmerican Solar DirectDr. Prescott
References
4
Case No. ADJ19183500
Regular
Jun 13, 2025

RICHARD ALFREDO MARAVILLA vs. POOL TIME POOL SERVICE, INC., INSURANCE COMPANY OF THE WEST

The Workers' Compensation Appeals Board granted reconsideration of a March 11, 2025 Findings and Order that denied the applicant's injury claim and the lien of Spectrum Medical Group. The Board found that Dr. Amin Nia was properly designated as the primary treating physician and that his medical-legal report was valid under Labor Code sections 4060, 4620, and 4621. The prior findings were rescinded, and the case was returned to the WCJ to determine the amount of defendant's liability for medical-legal expenses.

Adjudication NumberPetition for ReconsiderationFindings and OrderLien claimantPrimary Treating PhysicianMedical-Legal ReportContested ClaimLabor Code Section 4060Labor Code Section 4620Labor Code Section 4621
References
4
Case No. ADJ4280526 (OXN 0148727)
Regular
Dec 09, 2013

CLARA ARBIZU vs. WESTAC, INC., WAUSAU INSURANCE COMPANY

This case concerns an applicant's request for the defendant to prepay the cost of a vocational expert. The Appeals Board affirmed the original decision that defendants are not obligated to prepay these expenses. However, the Board clarified that vocational expert costs are considered medical-legal expenses under Labor Code section 4620 et seq., and defendants are liable for reasonable and necessary expenses incurred for proving or disproving a contested claim. The parties are ordered to proceed with a vocational expert evaluation, with the defendant ultimately responsible for the costs.

ArbizuVocational expertPrepaymentMedical-legal expenseLabor Code Section 4620Labor Code Section 4621Labor Code Section 5811Labor Code Section 5708Ogilvie analysisWhole Person Impairment
References
5
Case No. ADJ8060110, ADJ8060106
Regular
Sep 28, 2018

VICTOR SANTOYO vs. WEST CENTRAL PRODUCE, ZENITH INSURANCE COMPANY

The Workers' Compensation Appeals Board denied reconsideration of a lien claim for medical-legal expenses. The claimant failed to prove a contested claim existed at the time the expenses were incurred, a prerequisite for employer liability under Labor Code sections 4620 and 4621. Copy service fees for medical records are considered medical-legal expenses, but the claimant bore the burden of proving their necessity and the existence of a contested claim. The Board adopted the WCJ's report, excluding discussion on the "existence of contested claim" from their specific reasoning.

Workers' Compensation Appeals BoardVictor SantoyoWest Central ProduceZenith Insurance CompanyPetition for ReconsiderationDenyLabor Code Section 4622Medical-Legal ExpensesLien ClaimantContested Claim
References
5
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