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

Case No. SRO 0088351
En Banc
Mar 20, 2002

Cheryl Coldiron vs. Compuware, Gallagher Bassett Services, Inc.

The Appeals Board issued a notice to hold a conference and consider sanctions against a third-party administrator for failing to disclose the correct insurance carrier for the employer for over six years, causing significant confusion and delay.

WCABEN BANCCompuwareGallagher Bassett ServicesReliance National Insurancepermissibly self-insuredhigh self-insured retentionadjusting agentsanctionsLabor Code section 5813
References
8
Case No. SRO 0088351
Significant

Cheryl Coldiron, Applicant vs. Compuware Corporation, California Insurance Guarantee Association

The Appeals Board affirmed a prior award, substituting the correct insurance carrier for the employer and establishing that third-party administrators must disclose their client's identity in all proceedings.

Third-party administrator disclosureInsurance Guarantee AssociationReliance National Insurance CompanyCompuware CorporationGallagher Bassett ServicesInc.High self-insured retentionPolicy provisionsLabor Code section 5813 sanctionsInsurance Code sections 11650 et seq.
References
7
Case No. SRO 0088351
Significant
Mar 20, 2002

Cheryl Coldiron vs. Compuware; Permissibly Self-Insured, by And through Gallagher Bassett Services, Inc., Adjusting Agent

The board issues a notice of intent to sanction a third-party administrator for failing to disclose the correct insurance carrier for over six years and schedules a conference to clarify the employer-insurer relationship.

Workers' Compensation Appeals BoardEn BancPetition for ReconsiderationFindings and AwardPermissibly Self-InsuredThird-Party AdministratorHigh Self-Insured RetentionSanctionsLabor Code Section 5813Excusable Error
References
5
Case No. SRO 0088351
En Banc

Cheryl Coldiron vs. Compuware Corporation, California Insurance Guarantee Association, Reliance National Insurance Company (in liquidation), Intercare Insurance Services, Gallagher Bassett Services, Inc.

The Appeals Board held that a third-party administrator must disclose the identity of its client (employer or insurance carrier) and amended the award to be against the insurer, which had gone into liquidation and was succeeded by CIGA.

Workers' Compensation Appeals BoardThird-party administratorDisclosureSanctionsLabor Code Section 5813Insurance Code Sections 11650116571165911660Gallagher Bassett Services
References
7
Case No. SJO 0255977
Regular
May 20, 2008

GRACIELA RAMOS vs. ENTERPRISE RENT A CAR

The Appeals Board denied Enterprise Rent-A-Car's Petition for Reconsideration, upholding the finding of industrial spine injury and 28% permanent disability based on the prior rating schedule. The Board remanded the case to the trial level to clarify the employer's self-insurance and adjustment status, given a contradictory statement from the defendant. This clarification is to determine if sanctions against the defendant are warranted for failing to properly disclose administrative information, as per *Coldiron v. Compuware*.

Workers' Compensation Appeals BoardReconsideration DeniedFindings Award and OrderIndustrial InjurySpine InjuryPermanent DisabilityPrior Rating ScheduleLabor Code section 4061Third-Party AdministratorFrank Gates Services
References
1
Case No. ADJ3633276 (SAC 0360146)
Regular
Jan 24, 2012

GAYE MARTIN vs. LENNAR CORPORATION, BROADSPIRE

The Workers' Compensation Appeals Board denied the Petition for Removal filed by defendants Lennar Corporation and its third-party administrator, Broadspire. The Board adopted the WCJ's report, which recommended denial because the applicant's request to take the case off calendar was granted to allow her to develop her case under a recent *Ogilvie* decision. Additionally, the defendants were admonished for Broadspire's failure to disclose the identity of its client as required by *Coldiron v. Compuware Corp.* and were put on notice that sanctions could be considered at the trial level.

WCABRemovalBroadspireThird-party administratorColdironLabor Code section 3700SanctionsLabor Code section 5813Off calendarMandatory Settlement Conference
References
2
Case No. ADJ7445107
Regular
Oct 13, 2025

JILLIAN DIFUSCO vs. HANDS ON SPA, EMPLOYERS COMPENSATION INSURANCE GROUP

The Appeals Board, en banc, granted reconsideration of a WCJ's decision regarding disclosure requirements for defendants. The WCJ had ruled that the defendant only needed to disclose the name of its insurance carrier as per WCAB Rule 10390. The Board determined that its prior en banc decisions, Coldiron I and II, are binding precedent and require defendants to disclose all entities liable for payment and any insurance policy provisions affecting liability. Consequently, the WCJ's Findings of Fact and Order were rescinded, and the matter was returned to the trial level for further proceedings consistent with this comprehensive disclosure mandate.

En Banc DecisionWCAB Rule 10390Coldiron IColdiron IIDiscovery RequestInsurance Carrier DisclosureSelf-Insured RetentionLarge DeductibleEntity Liable for CompensationThird-Party Administrator
References
25
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