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

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 The Appeals Board rescinded the WCJ's findings and remanded the case for further proceedings on the provider's burden of proof.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. 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. ADJ1624407 (VNO 0535954)
Regular
Oct 21, 2010

ALFREDO SEPULVEDA vs. WARNER BROS., PSI, PARAMOUNT PICTURES, PSI, CAST & CREW ENTERTAINMENT, ZURICH NORTH AMERICA, ENTERTAINMENT PARTNERS, AMERICAN CASUALTY CO. OF READING, PA

The Appeals Board dismissed Warner Brothers' petition for removal, finding it was not the proper procedural vehicle to challenge the WCJ's order awarding medical-legal transportation and lodging expenses. The Board also denied the petition as a petition for reconsideration by operation of law, as it was filed more than 60 days prior. Even if the merits were considered, the petition would have been denied. The employer's arguments regarding Labor Code section 4621(d) and the doctor's report were implicitly rejected.

Workers' Compensation Appeals BoardPetition for RemovalPetition for ReconsiderationQualified Medical EvaluatorMedical-Legal TransportationLodging ExpenseLabor Code Section 4621(d)Substantial EvidenceFalse HistoryWCJ Report
References
1
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. 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. 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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