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

Case No. ADJ1197547
Regular
Apr 02, 2013

RAMON LARIOS vs. STAFFMARK INC. WEST, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION FOR ATLANTIC INSURANCE COMPANY in liquidation

The Workers' Compensation Appeals Board denied reconsideration of an order dismissing N-Care's lien claim. N-Care failed to pay the required $100 lien activation fee before their lien conference, and a stipulation was entered acknowledging this failure. While N-Care paid the fee shortly after the order of dismissal was issued, the Board found this was not timely compliance with the regulation requiring payment prior to the lien conference or at its commencement. The Board adopted the judge's reasoning that payment "at" the hearing meant at the time the hearing commenced, not at some later point during the same day.

Lien activation feeDWC emergency regulation 10208(a)Labor Code section 4903(b)Petition for ReconsiderationOrder Dismissing LienDeclaration of Readiness to Proceedlien conferenceworkers' compensation administrative law judgeEAMS systemdisposition
References
0
Case No. ADJ1723558
Regular
Jul 01, 2013

OMAR JACINTO vs. EXCEL DIRECT, FRYE CLAIMS

The Workers' Compensation Appeals Board (WCAB) denied a lien claimant's petition for reconsideration. The WCAB affirmed the dismissal of the lien claimant's claim because they failed to pay the required lien activation fee prior to the commencement of the lien conference as mandated by Labor Code §4903.06(a)(4) and the en banc decision in *Figueroa v. B.C. Doering Co*. The claimant's argument that they paid the fee during the conference was rejected, as proof of payment must be presented at the scheduled commencement time. The Appeals Board emphasized a bright-line rule regarding the timely payment of this fee.

Lien claimantLien activation fee (LAF)Petition for ReconsiderationWorkers' Compensation Appeals Board (WCAB)Lien conferenceDismissal with prejudiceLabor Code §4903.06(a)(4)Figueroa v. B.C. Doering Co.Proof of paymentCommencement of lien conference
References
1
Case No. ADJ6981750
Regular
Jan 13, 2017

GUMERSINDO DELEON vs. ESPARZA ENTERPRISES, INC.

This case concerns a lien claimant's failure to pay a $100.00 lien activation fee required by Labor Code section 4903.06 by the date of a lien conference. The Workers' Compensation Appeals Board (WCAB) is considering rescinding the order dismissing the lien, but only if the fee is paid within ten days of this notice. The WCAB's intention is based on a court order allowing lien activation fees to be paid between November 9, 2015, and December 31, 2015, and the lien claimant's assertion of computer problems. If payment is received, the lien claim will be returned to the trial level for further proceedings.

Lien activation feeLabor Code Section 4903.06ReconsiderationOrder Dismissing Lien ClaimWCJDWCAngelotti Chiropractic v. BakerPreliminary injunctionNinth CircuitVacating injunction
References
7
Case No. ADJ1035201
Regular
Oct 04, 2016

VICTOR DURAN vs. DONUT INN, STATE FARM INSURANCE COMPANY

The Appeals Board is considering rescinding an order that dismissed Metro Med Shockwave's lien claim for failure to pay a $\$100$ lien activation fee. The WCJ dismissed the lien because the fee was not paid before the lien conference, citing prior precedent. However, the lien claimant argues they had until December 31, 2015, to pay the fee based on a DWC Newsline article referencing a court order. The Board intends to rescind the dismissal if the fee is paid within ten days, allowing further proceedings on the lien claim.

Labor Code section 4903.06Lien activation feeWorkers' Compensation Appeals BoardMetro Med ShockwaveFigueroa v. B.C Doering Co.Angelotti Chiropractic v. BakerPreliminary injunctionDWC NewslineReconsiderationRescind order
References
2
Case No. ADJ7446809
Regular
Apr 17, 2013

JOE RAMIREZ vs. THE KROEGER COMPANY/RALPHS

The Workers' Compensation Appeals Board denied reconsideration of a decision dismissing Amy Swei's lien claim. The dismissal was based on the lien claimant's failure to pay a mandatory $100 lien activation fee prior to the scheduled lien conference, as required by Labor Code Section 4903.06(a)(4). The administrative law judge found the fee was paid after the 8:30 AM conference commenced, making the payment untimely. The Board adopted the judge's reasoning, emphasizing the clear language of the Labor Code mandating payment before the conference.

WCABADJ7446809Petition for ReconsiderationDWCemergency rule 10208(a)Labor Code section 4903(b)lien activation feeDeclaration of Readiness to Proceedlien conferenceOrders Dismissing Lien Claim
References
1
Case No. ADJ7564894
Regular
Jun 07, 2013

FLOR DE MARIA DE LEON vs. PORTO'S BAKERY, INC, TRAVELERS

Here's a summary for a lawyer: This case involves a lien claimant, First Choice Health UBC, whose lien was dismissed for failure to provide proof of timely payment of the lien activation fee at a lien conference. While the claimant's representative appeared for "FCH" and later submitted proof of payment for a different, similarly named entity (First Choice Medical Group), no proof was provided for First Choice Health UBC itself. The WCJ recommended denial of reconsideration, finding that the claimant failed to meet the requirements of Labor Code section 4903.06(a)(4) by not presenting evidence of activation fee payment for the correct entity at the conference, thus warranting dismissal with prejudice. The Appeals Board adopted the WCJ's report and denied the petition.

Lien ClaimantActivation FeePetition for ReconsiderationDismissal with PrejudiceContinuous TraumaServerBack InjuryKnee InjuryLower ExtremitiesNervous/Psyche
References
0
Case No. ADJ8229800
Regular
Oct 08, 2013

JULIO LOPEZ vs. TJS CONSTRUCTION, STATE COMPENSATION INSURANCE FUND

Here's a concise summary for a lawyer: The Workers' Compensation Appeals Board denied Bodner Chiropractic's Petition for Reconsideration, upholding the dismissal of its lien claim for failure to pay the required activation fee. Bodner's assertion that it couldn't locate the lien or pay the fee prior to the conference was insufficient to excuse the non-payment. While the Board found no clear proof the petition was untimely, the core reason for denial remains the lien claimant's failure to meet the activation fee payment deadline. The decision reiterates that lien activation fees must be paid before a lien conference commences.

Lien activation feeElectronic Adjudication Management System (EAMS)Petition for ReconsiderationWorkers' Compensation Appeals Board (WCAB)Lien claimantWorkers' Compensation Administrative Law Judge (WCJ)Dismissing Lien ClaimLabor Code section 4903.06Figueroa v. B.C. Doering Co.Compromise and Release
References
1
Case No. ADJ7711093
Regular
Nov 10, 2014

Fernando Sosa vs. Source One Staffing, CIGA by its Servicing Facility Patriot Risk Services, For Ullico, in liquidation

The Workers' Compensation Appeals Board dismissed a lien claimant's petition for reconsideration because it was unverified. The Board also granted removal on its own motion due to the lien claimant's repeated failure to appear at lien conferences and file proper objections. This conduct, along with filing an invalid petition, suggests potential bad faith and warrants a Commissioner's Conference to determine if sanctions should be imposed. The lien claim was ultimately dismissed by the WCJ for non-appearance.

Workers' Compensation Appeals BoardFernando SosaSource One StaffingCIGAUllicoPetition for ReconsiderationLien ClaimantCalifornia Physician NetworkLLCDenise Mejia
References
2
Case No. ADJ3132417 (AHM 0147500)
Regular
Oct 11, 2013

BRIAN FANNING vs. NISSAN OF GARDEN GROVE, PACIFIC COMPENSATION INSURANCE COMPANY

This case concerns a defendant's petition to remove an order from the Workers' Compensation Appeals Board regarding a medical lien. The defendant argued the lien claimant failed to pay the required activation fee before the lien conference, violating Labor Code section 4903.06(a)(4). The Board found the fee was paid after the conference commenced, and proof of payment wasn't provided, warranting dismissal with prejudice. The Board granted the petition and amended the prior order to dismiss the lien.

Petition for RemovalLien Activation FeeLien ConferenceDismissed with PrejudiceLabor Code Section 4903.06WCABEAMSOrder Approving Compromise & ReleaseWCJLien Trial
References
1
Case No. ADJ3274228
Significant
Apr 25, 2013

Eliezer Figueroa, Applicant vs. B.C. Doering Co.; Employers Compensation Insurance Co.

This en banc decision holds that if a lien claimant fails to pay the required lien activation fee prior to the commencement of a lien conference, the lien must be dismissed with prejudice.

Lien activation feeLabor Code section 4903.06Declaration of Readiness to Proceedlien conference commencementdismissal with prejudiceproof of paymenten banc decisionprecedentOrthomed LLCWCJ
References
4
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