Updated Daily

Case Law Database

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

Case No. ADJ4047184 (RDG 0115958)

Regular

Dec 02, 2009

BRICE SANDHAGEN vs. STATE COMPENSATION INSURANCE FUND

The court affirmed the WCJ's decision that the defendant was barred from relying on the utilization review process due to missed deadlines. The UR process is the employer's only avenue for resolving treatment requests.

RemittiturUtilization ReviewLabor Code section 4610(g)(1)Labor Code section 4062(a)Treating Physician RecommendationWCJFindings and Award and OrderPetition for ReconsiderationEn Banc DecisionCourt of Appeal

References

Case No. MISSING

En Banc

Feb 07, 2005

Brice Sandhagen vs. Cox & Cox Construction, Inc.; State Compensation Insurance Fund

The Appeals Board dismisses the applicant's petition for reconsideration, finding it premature because it was filed in response to an interlocutory order that remanded the case for further proceedings, rather than a final decision.

Labor Code 4610Labor Code 4062(a)Utilization ReviewQME/AMEPetition for ReconsiderationFinal OrderInterlocutory OrderRescinded DecisionRemanded MatterMandatory Deadlines

References

Case No. RDG 0115958

En Banc

Nov 16, 2004

Brice Sandhagen vs. Cox & Cox Construction, Inc.; State Compensation Insurance Fund

The Appeals Board held that utilization review time deadlines under Labor Code section 4610(g)(1) are mandatory. A defendant's failure to comply precludes the use of the utilization review process, renders the resulting report inadmissible, and requires the defendant, as the objecting party, to follow the dispute resolution procedures of section 4062(a).

Workers' Compensation Appeals BoardUtilization ReviewLabor Code Section 4610(g)(1)Mandatory DeadlinesAdmissibility of EvidenceACOEM GuidelinesTreating PhysicianMedical Treatment RecommendationAgreed Medical Evaluator (AME)Qualified Medical Evaluator (QME)

References

Case No. RDG 0115958

Significant

Nov 16, 2004

Brice Sandhagen, Applicant vs. Cox & Cox Construction, Inc.; State Compensation Insurance Fund

The Appeals Board held that the utilization review time deadlines are mandatory; if a defendant fails to meet these deadlines, any utilization review report is inadmissible, and the defendant must use the AME/QME procedure as the objecting party.

Workers' Compensation Appeals BoardUtilization ReviewLabor Code Section 4610Time DeadlinesAdmissibility of EvidenceMedical Treatment RecommendationACOEM GuidelinesAgreed Medical EvaluatorQualified Medical EvaluatorSection 4062

References

Case No. RDG 0115958

Significant

Brice Sandhagen, Applicant vs. Cox & Cox Construction, Inc., State Compensation Insurance Fund

The Board dismisses the applicant's petition for reconsideration because it was made from an interlocutory (non-final) order, as the matter had been remanded to a WCJ for further proceedings. The Board also observes that utilization review is not a mandatory prerequisite for a defendant to use the QME/AME process.

WORKERS' COMPENSATION APPEALS BOARDEN BANCOPINION AND ORDER DISMISSING PETITION FOR RECONSIDERATIONBrice SandhagenCox & Cox ConstructionInc.State Compensation Insurance FundLabor Code section 4610(g)(1)utilization reviewWCJ

References

Case No. ADJ16034617; ADJ13224263; ADJ9403331

Regular

Aug 12, 2025

DARREL LINK vs. NORTHROP GRUMMAN SYSTEMS CORPORATION, AIU INSURANCE COMPANY

Defendant sought reconsideration of a WCJ's finding that its Utilization Review (UR) process certified a Request for Authorization (RFA) and that the court lacked jurisdiction to alter this determination, while also ordering defendant to authorize treatment. The Appeals Board granted reconsideration to admit trial exhibits and amend findings of fact regarding the UR determination. The Board affirmed the WCJ's decision, concluding that the November 16, 2023 UR decision was timely and valid, and that the WCJ appropriately exercised authority to order compliance with the UR determination.

Utilization ReviewRequest for AuthorizationMedical NecessityFindings of FactPetition for ReconsiderationJurisdictionDue ProcessLabor Code Section 4610Aircraft MechanicTraumatic Brain Injury

References

Case No. ADJ71 43769

Regular

May 11, 2016

CURTIS KLEIN vs. WARNER BROS. STUDIO

This case involves a dispute over reimbursement for medical treatment provided by Dr. Marina Russman and other lien claimants. The defendant, Warner Bros. Studio, argued that Dr. Russman's treatment requests should not have been authorized because they were not submitted by the applicant's primary treating physician and therefore did not trigger the utilization review (UR) process. The Appeals Board affirmed the original award, holding that requests for authorization from secondary treating physicians do trigger the UR process. The Board also found substantial evidence supported the reasonableness and necessity of Dr. Russman's treatment, rejecting the defendant's argument that the applicant's condition was due to a pre-existing injury. Finally, a clerical error in the original order regarding a lien claimant was corrected.

Workers' Compensation Appeals BoardCurtis KleinWarner Bros. StudioPermissibly Self-InsuredOpinion and Decision After ReconsiderationPetition for ReconsiderationFindings of Fact Orders and AwardAdministrative Law Judge (WCJ)Lien ClaimantsDr. Marina Russman

References

Case No. ADJ1209163 (RDG 0121431) MF ADJ6630884

Regular

Dec 04, 2015

DOUG LEE vs. QUALITY TIMBER FALLING, STATE COMPENSATION INSURANCE FUND

This case involved an applicant seeking reimbursement for self-procured medication following utilization review (UR) denials. The Workers' Compensation Appeals Board (WCAB) determined that the statutory time limits for Independent Medical Review (IMR) are directory, not mandatory, making the IMR determinations valid despite delays. The WCAB found the defendant liable for reimbursement of self-procured medication due to overturned UR denials, but rescinded the penalty and attorney's fees for unreasonable delay.

Independent Medical ReviewUtilization ReviewLabor Code Section 4610.6(d)Directory vs. Mandatory ProvisionsMedical Treatment DisputesSB 863Medical Treatment Utilization ScheduleSelf-Procured MedicationSection 5814 PenaltyAttorney's Fees

References

Case No. ADJ4503834 (VNO 0113665) ADJ3103605 (VNO 0113666) ADJ2309113 (VNO 0113667) ADJ2270309 (VNO 0113668)

Regular

May 18, 2009

MARIA GARCIA vs. CITY OF LOS ANGELES

The Appeals Board dismissed the applicant's petition for reconsideration as it was not from a final order. However, the Board granted removal, rescinded the WCJ's order suspending submission, and returned the case for further proceedings. The WCJ improperly suspended proceedings without statutory authority and failed to resolve issues including utilization review compliance under *Sandhagen*. The Board ordered the WCJ to first address *Sandhagen* issues and proper utilization review before any further medical record development.

Petition for ReconsiderationPetition for RemovalOrders Suspending Submissionsubstantial evidenceutilization reviewuntimelyunsignedpenaltyattorney's feesneglect and delay

References

Case No. ADJ7136909

Regular

Apr 16, 2014

BRUCE TABARACCI vs. WASTE MANAGEMENT, ACE AMERICAN, GALLAGHER BASSETT

The Workers' Compensation Appeals Board denied the defendant's petition for reconsideration and dismissed their petition for removal. The Board adopted the findings of the Administrative Law Judge, who recommended denial. The defendant's arguments, including claims that utilization review (UR) denials were not defective and that Dr. Light's reports were inadmissible, were rejected. The Board found the UR process was procedurally deficient due to the defendant failing to provide all relevant medical records.

Workers' Compensation Appeals BoardPetition for ReconsiderationPetition for RemovalWCJ Report and RecommendationLabor Code §4062IMR tractPrimary Treating Physician (PTP)Secondary Treating PhysicianUtilization Review (UR)Request for Medical Treatment Authorization

References

Showing 1-10 of 169 results

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Updated Daily

Case Law Database

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

Case No. ADJ4047184 (RDG 0115958)

Regular

Dec 02, 2009

BRICE SANDHAGEN vs. STATE COMPENSATION INSURANCE FUND

References

Case No. MISSING

En Banc

Feb 07, 2005

Brice Sandhagen vs. Cox & Cox Construction, Inc.; State Compensation Insurance Fund

Labor Code 4610Labor Code 4062(a)Utilization ReviewQME/AMEPetition for ReconsiderationFinal OrderInterlocutory OrderRescinded DecisionRemanded MatterMandatory Deadlines

References

Case No. RDG 0115958

En Banc

Nov 16, 2004

Brice Sandhagen vs. Cox & Cox Construction, Inc.; State Compensation Insurance Fund

References

Case No. RDG 0115958

Significant

Nov 16, 2004

Brice Sandhagen, Applicant vs. Cox & Cox Construction, Inc.; State Compensation Insurance Fund

References

Case No. RDG 0115958

Significant

Brice Sandhagen, Applicant vs. Cox & Cox Construction, Inc., State Compensation Insurance Fund

References

Case No. ADJ16034617; ADJ13224263; ADJ9403331

Regular

Aug 12, 2025

DARREL LINK vs. NORTHROP GRUMMAN SYSTEMS CORPORATION, AIU INSURANCE COMPANY

Utilization ReviewRequest for AuthorizationMedical NecessityFindings of FactPetition for ReconsiderationJurisdictionDue ProcessLabor Code Section 4610Aircraft MechanicTraumatic Brain Injury

References

Case No. ADJ71 43769

Regular

May 11, 2016

CURTIS KLEIN vs. WARNER BROS. STUDIO

References

Case No. ADJ1209163 (RDG 0121431) MF ADJ6630884

Regular

Dec 04, 2015

DOUG LEE vs. QUALITY TIMBER FALLING, STATE COMPENSATION INSURANCE FUND

References

Case No. ADJ4503834 (VNO 0113665) ADJ3103605 (VNO 0113666) ADJ2309113 (VNO 0113667) ADJ2270309 (VNO 0113668)

Regular

May 18, 2009

MARIA GARCIA vs. CITY OF LOS ANGELES

Petition for ReconsiderationPetition for RemovalOrders Suspending Submissionsubstantial evidenceutilization reviewuntimelyunsignedpenaltyattorney's feesneglect and delay

References

Case No. ADJ7136909

Regular

Apr 16, 2014

BRUCE TABARACCI vs. WASTE MANAGEMENT, ACE AMERICAN, GALLAGHER BASSETT

References

Showing 1-10 of 169 results

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