DIMAS POSADA vs. PARKWOOD LANDSCAPE & MAINTENANCE, EVEREST NATIONAL INSURANCE COMPANY
The Workers' Compensation Appeals Board (WCAB) dismissed a lien claimant's petition for reconsideration because it was filed untimely. The WCAB determined that the petition was submitted 36 days after the Order Dismissing Lien Claim was served, exceeding the statutory 20-day period plus an additional five days for mail service. As a result, the WCAB lacked jurisdiction to review the merits of the lien claimant's arguments. The lien claimant had argued the dismissal was due to a missed hearing caused by a file transfer and timely responded to a notice.