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

Case No. ADJ7673518, ADJ7647749
Regular
Jan 23, 2015

ANA DE AYALA vs. AO-THE UNIVERSITY CORPORATION / CALIFORNIA STATE UNIVERSITY NORTHRIDGE

The Workers' Compensation Appeals Board granted reconsideration and reversed a prior ruling, finding the applicant sustained industrial injury to her neck. While the applicant testified to injuring her neck in a workplace incident and this was partially corroborated, the Board found insufficient evidence for other claimed injuries. The Board specifically disagreed with the administrative law judge's credibility assessment concerning the neck injury itself, relying on medical reports and testimony supporting the neck injury claim. The Board affirmed the denial of claims for all other alleged injuries, finding insufficient medical evidence to link them to the incident.

Petition for ReconsiderationFindings and OrderIndustrial InjuryNeck InjuryBack InjurySpine InjuryUpper ExtremitiesPsycheGastroesophageal SystemInternal System
References
Case No. LAO 0864684
Regular
Nov 23, 2008

VICTORIA VEGA vs. ARAMARK, ACE, USA

The Workers' Compensation Appeals Board granted reconsideration and returned the case to the trial level for further proceedings. The Board found that the Medical Provider Network (MPN) notice issue was timely raised and requires further determination by the WCJ. Additionally, the WCJ must address the limits on chiropractic visits under Labor Code section 4604.5(d)(1) and other potential violations.

Medicallegal reportMedical Provider Network (MPN)Knight v. United Parcel ServiceLabor Code section 4616.3(b)Gee v. Workers' Comp. Appeals Bd.Labor Code section 4062.9Labor Code section 139.3Compromise and Release (C&R)Occupational Medicine Practice GuidelinesLabor Code section 4604.5(d)(1)
References
Case No. ADJ8266885
Regular
Jan 20, 2016

DAYSI PATRICIA MOLINA ROMERO vs. CALIFORNIA PIZZA KITCHEN, TRAVELERS DIAMOND BAR

This case involves a lien claim by Mario Arroyo, D.C., for chiropractic and physical therapy services provided to an injured worker. The Workers' Compensation Appeals Board (WCAB) granted reconsideration and rescinded the original findings. The WCAB held that "visits" must be distinguished by the type of treatment rendered, allowing for separate reimbursement caps for chiropractic and physical therapy visits. Further development of the record is required to determine the nature of services provided and whether Arroyo is entitled to reimbursement for physical therapy beyond the 24 chiropractic visits already paid.

Workers' Compensation Appeals BoardPetition for ReconsiderationFindings and OrderLien ClaimantChiropractic VisitsPhysical TherapyLabor Code Section 4604.5(c)(1)Bill ReviewerCumulative TraumaIndustrial Injury
References
Case No. ADJ1617135 (VNO 0419995)
Regular
Sep 26, 2016

JOHN WILLIAMS, Johnny Williams vs. REGIONAL TRANSPORT, INC., STATE COMPENSATION INSURANCE FUND, SCIF

This case concerns a workers' compensation claim for Johnny Williams, who sustained an industrial injury in 2000. The defendant, State Compensation Insurance Fund (SCIF), sought reconsideration of a decision that limited their liability for chiropractic visits. SCIF argued that a 24-visit cap should apply, but the Workers' Compensation Appeals Board denied their petition. The Board found that the 24-visit cap applies only to injuries occurring on or after January 1, 2004, and Williams' injury predates this. Furthermore, the Board found that the chiropractic treatment provided was reasonable and necessary, supported by evidence and medical guidelines.

Workers' Compensation Appeals BoardPetition for ReconsiderationAgreed Medical ExaminerChiropractic visitsMedical treatment utilization scheduleDate of injuryPermanent disabilityLien claimsReasonable and necessary treatmentACOEM Practice Guidelines
References
Case No. ADJ3861984
Regular
Sep 23, 2010

GUADALUPE SANTA CRUZ vs. PEP BOYS, GALLAGHER BASSETT ROSEVILLE

This case involves a lien claim by a chiropractor for over $67,000 for treatment provided to an injured worker. The Workers' Compensation Appeals Board (WCAB) affirmed a prior finding that only $66.94 was owed, disallowing the balance of the lien. The WCAB ruled that a statutory amendment effective in 2008 did not apply retroactively to services rendered prior to its effective date. Additionally, the lien claimant failed to prove licensure for physical and occupational therapy, and the stipulated medical treatment and AME opinions did not cover the disputed past services.

Labor Code section 4604.5(d)(3)retrospective applicationmedical treatment utilizationchiropractic visitsphysical therapy visitsoccupational therapy visitslumbar surgerystipulated awardAME reportsACOEM Guidelines
References
Case No. ADJ3141261 (LAO 0814644) ADJ3582498 (LAO 0815914)
Regular
Feb 09, 2009

MARIA DEL CARMEN CEJA vs. INTESYS TECHNOLOGIES, INC., BROADSPIRE

This case concerns a workers' compensation lien for chiropractic treatment. The administrative law judge previously ruled that only 24 visits were compensable under Labor Code Section 4604.5(d)(1). The Workers' Compensation Appeals Board granted reconsideration, finding this interpretation erroneous. The Board rescinded the prior finding and returned the matter for further proceedings, clarifying that the 24-visit limit applies only to injuries occurring on or after January 1, 2004, which these pre-2004 injuries do not.

Workers' Compensation Appeals BoardLien claimantReconsiderationLabor Code Section 4604.5Chiropractic visitsCompromise & ReleaseDate of injuryMedical treatment utilization schedulePresumptively correctRebuttable presumption
References
Case No. ADJ9313543; ADJ3093632
Regular
Sep 24, 2025

JAIME ORTIZ vs. CITY AUTO BODY, STATE COMPENSATION INSURANCE FUND

This case involves lien claimants seeking reconsideration of a Workers' Compensation Appeals Board decision regarding industrial injuries sustained by the applicant. The Board affirmed the disallowance of Dr. Mirza's lien for diagnostic services due to a lack of demonstrated medical necessity under the MTUS. The lien for chiropractic visits was affirmed, applying statutory visit limitations and postsurgical allowances. However, the issue of interpreter Mario Corzo's lien was deferred and returned to the trial level for further proceedings to determine his certification status under relevant guidelines.

ReconsiderationLien ClaimantsFindings of Fact and OrderChiropractic VisitsOfficial Medical Fee ScheduleMedically NecessaryCertified InterpreterLabor Code Section 4604.5Medical Treatment Utilization ScheduleDiagnostic Testing
References
Case No. SAL 0113062
Regular
Jan 02, 2008

, Maria LOURDES TAPIA, vs. REGENT ASSISTED LIVING, ALASKA NATIONAL INSURANCE

The Workers' Compensation Appeals Board denied reconsideration of a decision upholding a 24-visit limit for chiropractic treatment per industrial injury. The applicant argued that the statutory cap conflicted with the liberal construction mandate of Labor Code section 3202, but the Board found no ambiguity in the clear language of Labor Code section 4604.5(d)(1). The Board further clarified that the provision allowing employers to authorize additional visits in writing (LC 4604.5(d)(2)) did not remove the cap, nor did it render chiropractors meaningless within the workers' compensation system.

Workers' Compensation Appeals BoardPetition for ReconsiderationLabor Code Section 4604.5(d)(1)chiropractic visitsoccupational therapyphysical therapyLiberal constructionLabor Code Section 3202employer authorizationFindings & Order
References
Case No. ADJ1775959 (ANA 0387306) ADJ2257120 (ANA 0386617)
Regular
May 17, 2010

SILVIA MORA vs. STEELCASE, INC., LIBERTY MUTUAL INSURANCE COMPANY

The Workers' Compensation Appeals Board (WCAB) granted reconsideration and rescinded a prior decision that ordered a lien claimant to reimburse the defendant for chiropractic treatment exceeding the statutory limit. The WCAB held that Labor Code section 4604.5(d)(1) limits chiropractic visits but does not authorize restitution for voluntary payment of excessive treatment. Citing the equitable principles established in *American Psychometric Consultants, Inc. v. Workers' Compensation Appeals Board (Hurtado)*, the Board found that both parties were equally aware of the legal limits, and the defendant voluntarily paid the excess charges. The WCAB emphasized transactional stability, stating that undoing such payments would negatively impact the workers' compensation system.

Workers' Compensation Appeals BoardLien claimantReconsiderationFindings and OrderLabor Code section 4604.5(d)(1)Chiropractic visitsReimbursementPetition for ReimbursementMedical treatment lienEquitable restitution
References
Case No. ADJ2544321 (VNO 0546971)
Regular
Jan 04, 2010

PEDRO SERRATO vs. B & B DOORS & WINDOWS, INC., PRAETORIAN INSURANCE COMPANY C/O AMERICAN ALL RISK LOSS ADMINISTRATORS

The Workers' Compensation Appeals Board dismissed the defendant's Petition for Reconsideration as untimely, as it was filed 44 days after the deadline. The Board, however, corrected a clerical error in the original Findings and Award. The Judge had awarded $12,425.48 to a lien claimant, but the corrected award reflects the statutory limit of 24 chiropractic visits, along with physical therapy and acupuncture, totaling $3,740.61 based on expert testimony.

Workers' Compensation Appeals BoardPedro SerratoB & B Doors & WindowsPraetorian Insurance CompanyPacific Ortho & RehabilitationFindings and Awardclerical errorpetition for reconsiderationuntimelyLabor Code section 5903
References
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