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

Case No. ADJ7658730
Regular
Mar 27, 2014

Maria Perez vs. TS STAFFING, LUMBERMEN'S UNDERWRITING ALLIANCE

This case concerns a lien claim for interpretation services provided by Santana, Lopez & Associates, LLC. The Workers' Compensation Appeals Board granted reconsideration and rescinded the prior order, finding that Santana failed to prove its interpreters were "qualified" for 14 medical appointments. The interpreters for these appointments were neither certified nor provisionally certified, nor were they documented as provisionally utilized by the treating physician, thus invalidating the lien for those services. Consequently, Santana is not entitled to further payment on its lien.

Santana Lopez & AssociatesLumbermen's Underwriting Alliancequalified interpretercertified interpreterprovisionally certifiedGovernment Code section 11435.55Labor Code section 4622Labor Code section 4603.2(b)Labor Code section 5813Administrative Director's Rule 9795.1
References
Case No. ADJ8658755
Regular
Mar 22, 2018

JOSE ALCAIDE SIERRA vs. MARK BOWERS DRYWALL, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board denied reconsideration of an order awarding interpreter fees. The Board found that the award did not violate Rule 10451.3 because the interpreter services were rendered during a hearing, allowing the WCJ to assess their necessity and qualifications directly. Unlike situations requiring a formal petition for costs, the WCJ's personal observation and lack of objection from the defendant at the hearing supported the award. The Board also found the order sufficiently supported by the facts presented.

Petition for ReconsiderationAppeals Board Rule 10451.3Petition for CostsInterpreter feesLabor Code section 5710(b)(5)Administrative Director Rule 9795.3(a)(5)WCJHearingInterpreter qualificationsUnsupported order
References
Case No. ADJ3666697
Regular
Nov 18, 2010

JOSE GUADALUPE AGUAYO vs. THE PETERSEN COLLECTION, STATE COMPENSATION INSURANCE FUND

This case involves a lien claim by Global Interpreting for services provided to applicant Jose Guadalupe Aguayo. The trial judge denied the lien, finding that Spanish interpretation during medical treatment is not a compensable cost in Los Angeles, treating it as a normal business expense. The Appeals Board granted reconsideration, rescinded the denial, and returned the case for further proceedings. The Board held that the compensability of interpretation services must be assessed based on individual circumstances and evidence, not categorically denied due to the language or location.

Workers' Compensation Appeals BoardLien claimantReconsiderationFindings and OrderAdministrative law judgeInterpreting servicesLabor CodeReasonable and necessaryCompensabilityBurden of proof
References
Case No. ADJ1972276 (LAO 0862108) ADJ2914408 (LAO 0889233)
Regular
Mar 07, 2011

AMANDA CORONADO vs. BALLY'S TOTAL FITNESS, STATE COMPENSATION INSURANCE FUND

This case involves a lien claimant, E&M Interpreting, seeking payment for alleged interpretation services during the applicant's medical treatment. The Workers' Compensation Appeals Board denied reconsideration, upholding the administrative law judge's decision that E&M failed to meet its burden of proof. Specifically, E&M did not demonstrate the qualifications of its interpreters or the necessity of the services provided. The Board affirmed that lien claimants must prove both the reasonableness and necessity of services, as well as the qualifications of the individuals providing them, to be entitled to payment.

Workers' Compensation Appeals BoardLien claimantReconsiderationQualified interpretersBurden of proofInterpretation servicesMedical treatment appointmentsAdministrative law judgeFindings and OrderBilling
References
Case No. ADJ163338
Significant
Mar 17, 2011

Jose Guitron, Applicant vs. Santa Fe Extruders, State Compensation Insurance Fund

The Appeals Board held that under Labor Code section 4600, an employer is required to provide reasonably necessary interpreter services during medical treatment for an injured worker who cannot communicate effectively in English, and clarified the burden of proof for interpreter lien claimants.

En Banc DecisionInterpreter ServicesMedical TreatmentReasonably RequiredBurden of ProofQualified InterpreterLien ClaimantLabor Code Section 4600Medical-Legal ExpensesCertified Interpreter
References
Case No. ANA 0372945 ANA 0380241
Regular
May 06, 2008

OLGA A. SALDAÑA vs. 3M ESPE, LIBERTY MUTUAL INSURANCE COMPANY, SEDGWICK CLAIMS MANAGEMENT SERVICES

The Workers' Compensation Appeals Board reversed a prior decision, finding that interpreter services are reimbursable under Labor Code section 4600 when recommended or required by a treating physician. The Board determined that these services are considered part of the overall medical treatment benefit, analogous to transportation costs. Therefore, the lien claimant, Certified Interpreters, is entitled to payment for services rendered at both medical-legal evaluations and applicant's medical treatment appointments.

Labor Code section 4600interpreter servicesmedical-legal expensesmedical treatmentCertified InterpretersWorkers' Compensation Appeals Boardadministrative law judgereconsiderationAD Rule 9795.3case law
References
Case No. ADJ757747
Regular
Aug 09, 2010

CRISTINA BANDERAS vs. DIJON ENTERPRISES dba McDONALDS, ZENITH INSURANCE COMPANY

This case involves a lien claimant's petition for removal after a WCJ ordered the defendant to provide only medical reports the defendant intended to rely on. The Appeals Board granted removal, ordering the defendant to produce all medical reports in its possession, as required by regulation. The Board also struck a portion of the WCJ's order regarding proof of interpreter market rates, finding the issue was not properly before the WCJ. Finally, the Board found no evidence of bias by the WCJ and returned the case for further proceedings.

Workers' Compensation Appeals BoardRemovalLien ClaimantMedical ReportsWCJBiasInterpreter FeesMarket RateQualified InterpreterCertified Interpreter
References
Case No. ADJ9200986
Regular
Sep 04, 2014

JESUS LOPEZ vs. ADAM BROTHERS FARMING, INC., ZENITH INSURANCE COMPANY

The Appeals Board granted reconsideration to review a $2,500 sanction imposed by a WCJ on Ms. Tapia, a non-certified interpreter. Ms. Tapia contended the sanction was improperly issued without due process and that the WCJ erred in factual findings. The Appeals Board found the record inadequate and the WCJ's assertion that no order was issued contradicted the Minutes of Hearing. Therefore, the disposition order imposing sanctions was rescinded, and the matter was returned for further proceedings to develop a complete record and determine sanction appropriateness.

Workers' Compensation Appeals BoardReconsiderationSanctionUncertified InterpreterCompromise and Release AgreementMinutes of HearingWCJ Report and RecommendationDisqualificationPresiding WCJRescind
References
Case No. ADJ9742388
Regular
Dec 23, 2020

MIHN LUONG vs. GARDENA RESTAURANT INC., dba SEA EMPRESS RESTAURANT, STATE COMPENSATION INSURANCE FUND

This case concerns a lien claim for interpreter services. The Workers' Compensation Appeals Board (WCAB) rescinded prior findings and returned the matter for further proceedings. The key issue was whether the interpreter's declaration under Labor Code section 4903.05(c) was false when it stated services were for medical-legal examinations, but the services were primarily for medical treatment appointments. The WCAB agreed that expenses for interpreting at medical treatment appointments are allowed as a lien under the administrative director's rules. The WCAB also directed the judge to determine reimbursement for interpreting at a WCAB conference and for a Compromise and Release document.

Workers' Compensation Appeals BoardLien ClaimantLabor Code section 4903.05(c)Certified InterpreterMedical-Legal ExaminationsMedical TreatmentCompromise and ReleaseWCAB ConferenceFindings of FactReport and Recommendation
References
Case No. ADJ2454787 OXN 0130418, ADJ4243140 (OXN 0130419)
Regular
Dec 23, 2008

ALMALILIA MARTINEZ vs. TRACEY VILLA, NATIONAL FIRE INSURANCE OF HARTFORD, CNA CLAIMS PLUS

This case involves a lien claimant seeking reimbursement for interpreter services provided to a non-English speaking applicant during medical treatment appointments. The Appeals Board granted reconsideration, finding that interpreter services can be a compensable cost under Labor Code section 4600 as an adjunct to medical treatment. The matter is remanded for the Workers' Compensation Judge to determine the reasonableness and necessity of the interpreter services for treatment visits, and to re-evaluate penalties and interest.

Workers' Compensation Appeals BoardLien ClaimantReconsiderationJoint Findings and AwardIndustrial InjuryInterpreting ServicesLabor Code Section 4600Administrative Director Rule 9795.3Medical Treatment AppointmentsQualified Interpreter
References
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