Case Law Database

ROBERT DALLAS vs. PAN PACIFIC PETROLEUM, NATIONAL UNION FIRE INSURANCE COMPANY

This case concerns an applicant's industrial back injury and a dispute over authorization for spinal surgery. The defendant failed to provide a required second written notification of their Utilization Review (UR) decision to the applicant's physician and the applicant. Citing the *Bodam* precedent, the Appeals Board held that a UR decision, even if timely made, is invalid if not properly communicated. Consequently, the Board affirmed the Workers' Compensation Judge's award of surgery, determining its necessity based on available evidence.