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Case Law Database

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

Case No. ADJ8387626
Regular
Oct 29, 2015

ANA DIAZ vs. SAMBRAILO PACKAGING, INC., ZENITH INSURANCE COMPANY

This case involves a lien claim for photocopying services provided by California Imaging Solutions (CIS). The WCJ initially disallowed the lien because CIS was not registered as a professional photocopier, as required by Business and Professions Code section 22450. However, the Appeals Board granted reconsideration, finding that CIS was exempt from this registration requirement under Business and Professions Code section 22451(b) because it acted as an agent or independent contractor for applicant's attorney. The case is returned to the trial level to address record deficiencies and re-evaluate the lien claim's compensability in light of this exemption.

Lien ClaimantReconsiderationFindings And OrderAdministrative Law JudgeWCJProfessional PhotocopierBusiness and Professions Code Section 22450Business and Professions Code Section 22451(b)State BarAgent
References
3
Case No. ADJ8997883
Regular
Jan 04, 2016

PEDRO ALAVEZ vs. SAK'S TERIYAKI, ZENITH INSURANCE COMPANY

This case involves a lien claim by Western Imaging Services, Inc. (WIS) for copying services provided to applicant's attorney. The WCJ initially disallowed the lien, finding WIS failed to prove it was an independent contractor exempt from Business and Professions Code section 22450. The Appeals Board granted reconsideration, holding that WIS made a prima facie showing of exemption under Business and Professions Code section 22451(b) by acting as an agent or independent contractor for a State Bar member. Consequently, the case is returned to the trial level for a new decision on the lien claim.

Workers' Compensation Appeals BoardWestern Imaging ServicesInc.Business and Professions Code section 22451independent contractoragentState Barlien claimantreconsiderationPrima facie showing
References
1
Case No. ADJ8313132
Regular
2015-05-00

Ana Garcia vs. Exemplar Enterprise, Travelers Property Casualty Company of America

This case involves a lien claim by Preferred Scan, Inc. (PSI) for photocopying services provided to the applicant's attorney. The initial ruling disallowed PSI's lien, finding it failed to meet registration and bonding requirements for professional photocopiers under Business and Professions Code sections 22450 and 22455. The Workers' Compensation Appeals Board (WCAB) reversed this decision, holding that PSI was exempt as an independent contractor of a member of the State Bar pursuant to Business and Professions Code section 22451(b). The WCAB found sufficient evidence that PSI acted as an agent or independent contractor for the attorney, thus making registration and bonding unnecessary. The case was returned to the trial level to determine the amount due on PSI's lien.

Workers' Compensation Appeals BoardLien ClaimantPetition for ReconsiderationFindings and OrderAdministrative Law JudgeIndependent ContractorBusiness and Professions Code Section 22451Registration RequirementsBonding RequirementsMember of the State Bar
References
9
Case No. ADJ9351964 ADJ9351965
Regular
Mar 15, 2016

ROGELIO CORNEJO vs. YOUNIQUE CAFÉ, INC., ZENITH INSURANCE COMPANY

In this case, the Workers' Compensation Appeals Board granted reconsideration of its prior en banc decision. The prior decision held that Chapter 20 of Division 8 of the Business and Professions Code did not apply to a copy service lien claimant acting as an agent or independent contractor for a lawyer. Consequently, proof of registration and bonding under Business and Professions Code sections 22450 and 22455 was deemed unnecessary in such circumstances. The Board granted reconsideration to further study the factual and legal issues presented.

Workers' Compensation Appeals BoardYounique CaféZenith Insurance CompanyWestern Imaging ServicesInc.Rogelio CornejoPetition for ReconsiderationEn BancChapter 20Business and Professions Code
References
0
Case No. MISSING
Regular Panel Decision
May 08, 2007

Canal Carting, Inc. v. City of New York Business Integrity Commission

Petitioners Canal Carting, Inc. and Canal Sanitation, Inc., long-standing private sanitation businesses, challenged the Business Integrity Commission's (BIC) denial of their license renewals. The BIC cited Canal's knowing failure to provide required documentation, inability to demonstrate eligibility, and two violations for illegal dumping and operating an illegal transfer station. Canal argued the findings were arbitrary, capricious, and unprecedented, insisting their financial issues were unrelated to organized crime, which Local Law 42 (governing BIC) aimed to combat. The court found no due process violation regarding a formal hearing but concluded that the BIC's denial, effectively closing Canal's 50-year business for what amounted to poor business management, was arbitrary, unduly harsh, and shocking to one's sense of fairness. Consequently, the court granted the petition, annulled the BIC's denial, and remanded the case for reconsideration.

License RenewalAdministrative LawArticle 78 ProceedingBusiness Integrity CommissionTrade Waste IndustryDue ProcessArbitrary and CapriciousJudicial ReviewLocal Law 42Financial Responsibility
References
6
Case No. ADJ8883051
Regular
Nov 03, 2015

ROSEMARY BARRIENTOS vs. SABAN FREE CLINIC, CYPRESS INSURANCE COMPANY

The Workers' Compensation Appeals Board granted reconsideration of a decision disallowing Western Imaging Services' (WIS) lien. The Board found WIS was exempt from photocopier registration requirements as it acted as an agent for applicant's attorney, a member of the State Bar. This exemption, under Business and Professions Code Section 22451(b), negates the need for registration and bonding. The case was returned to the trial level for a new decision on the lien's compensability and fee.

Workers' Compensation Appeals BoardLien ClaimantPetition for ReconsiderationBusiness and Professions Code Section 22451(b)Independent ContractorAgentState BarRegistration RequirementsBondingProfessional Photocopier
References
9
Case No. ADJ8928907
Regular
Oct 29, 2015

NOEL CARMONA vs. SUN VALLEY PRODUCTS, INC., INSURANCE COMPANY OF THE WEST

The Workers' Compensation Appeals Board granted reconsideration for lien claimant Western Imaging Services, Inc. (WIS). WIS had its lien claim disallowed because it failed to prove registration as a professional photocopier. The Board found that WIS was exempt from registration under Business and Professions Code § 22451(b) as it acted as an agent or independent contractor for applicant's attorney, a member of the State Bar. Consequently, the prior decision was rescinded, and the case was returned for further proceedings on the lien amount.

Workers' Compensation Appeals BoardNoel CarmonaSun Valley Products Inc.Insurance Company of the WestWestern Imaging Services Inc.lien claimantpetition for reconsiderationadministrative law judgeBusiness and Professions Code section 22450Business and Professions Code section 22451(b)
References
3
Case No. ADJ8093832
Regular
Sep 24, 2015

ARACELI CASILLAS DE VAZQUEZ vs. EL TAPATIO MARKET, ZENITH INSURANCE COMPANY

Lien claimants Western Imaging Services and Tower Copy Service petitioned for reconsideration after their liens were denied by the WCJ. The WCJ had ruled they were unregistered professional photocopiers and not exempt from registration requirements. The Appeals Board granted reconsideration, finding that the lien claimants were indeed independent contractors of applicant's attorney, a member of the State Bar. Therefore, they qualified for the exemption under Business and Professions Code section 22451(b). The case was remanded for a determination of the reasonableness of the claimed fees.

Professional photocopierBusiness and Professions Code Section 22450Business and Professions Code Section 22451Independent contractor exemptionMember of the State BarLien claimantsWorkers' Compensation Appeals BoardPetition for reconsiderationDecision after reconsiderationWCJ
References
0
Case No. ADJ6733204
Regular
Aug 11, 2014

MARIA TORRES vs. MAG INSTRUMENTS, INC.; PACIFIC COMPENSATION INSURANCE COMPANY

The Workers' Compensation Appeals Board denied reconsideration in this case. The lien claimant, Western Imaging Services, failed to present any evidence at the lien trial to support its claim for reimbursement for medical-legal services. Specifically, no evidence was introduced to establish Western Imaging Services' status as a licensed professional photocopier or its exemption from licensing requirements under Business and Professions Code §22451(b). The Board adopted the WCJ's report, emphasizing that merely filing a document does not constitute evidence.

Workers' Compensation Appeals BoardPetition for ReconsiderationLien ClaimantBusiness and Professions CodeProfessional PhotocopierLicensing RequirementMedical-Legal ServicesBurden of ProofWCJ ReportState Bar Exemption
References
0
Case No. ADJ8674944
Regular
Sep 28, 2015

CECILIA ROSALES vs. KING TACO RESTAURANT, AMERICAN CASUALTY COMPANY

This case concerns a lien claim by Western Imaging Services (WIS) for photocopying services rendered to applicant's attorney. The original decision disallowed the lien, finding WIS was not an independent contractor exempt from registration and bonding requirements under Business and Professions Code § 22451(b). The Appeals Board granted reconsideration, finding that WIS *was* an independent contractor of the attorney based on submitted evidence and the plain language of the statute. Therefore, WIS is exempt from registration, and its lien is allowed, with penalties deferred.

Workers' Compensation Appeals BoardLien ClaimantPetition for ReconsiderationDecision After ReconsiderationIndependent ContractorBusiness and Professions CodeRegistration RequirementsBonding RequirementState BarProfessional Photocopying
References
4
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