CompFox Logo
AboutWorkflowFeaturesPricingCase LawInsights

Updated Daily

Case Law Database

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

Case No. ADJ9248422, ADJ9247183
Regular
Sep 12, 2019

VERONICA VASQUEZ vs. EAST COAST FOODS, dba ROSCOE'S HOUSE OF CHICKEN AND WAFFLES, STATE COMPENSATION INSURANCE FUND

This case concerns the validity of liens filed by medical providers and interpreters. The Workers' Compensation Appeals Board granted reconsideration and rescinded a prior order, finding that the declarations supporting the liens were invalid because the declarant, Ilona Kulikova, lacked personal knowledge. The Board dismissed one lien completely due to the lack of any other valid declaration. However, for two other liens, the Board remanded the case to allow the trial judge to reconsider additional declarations that were not initially evaluated.

Labor Code section 4903.8DeclarationPersonal knowledgeCompetent to testifyElectronic signatureLien claimantsAmended declarationsDue processJoint Findings and OrderPetition for Reconsideration
References
Case No. ADJ9835949; ADJ9835948; ADJ9860843
Regular
Sep 29, 2025

EDGAR ARAGON-ZARATE vs. MODERN AUTO CENTER, STATE COMPENSATION INSURANCE FUND

Lien claimant Joyce Altman Interpreting sought reconsideration of a Joint Findings and Order issued by a WCJ, which dismissed their lien for interpreting services due to alleged false or inaccurate information in their declaration under Labor Code section 4903.05(c). The Workers' Compensation Appeals Board (WCAB) rescinded the F&O, noting ambiguity in the record regarding whether the defendant denied all liability at the time the interpreting services were rendered. The WCAB emphasized that interpreting services are an integral part of medical treatment and returned the matter for further proceedings to develop the record.

Labor Code section 4903.05(c)Lien claimant declarationInterpreting services lienMedical treatment expensesDeclaration accuracyDue processExcusable neglectRescind OrderReturn to trial levelWCAB
References
Case No. ADJ10344350; ADJ10344309
Regular
Sep 29, 2025

JUAN SALAZAR vs. MAYWOOD PLAZA MARKET, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board (WCAB) granted reconsideration of a prior decision by a workers' compensation administrative law judge (WCJ) concerning lien claimants Industrial Healthcare PMG, Complete Interpreting, and Peralta Hills-Mission Valley Imaging. The WCJ had dismissed their liens, finding their declarations under Labor Code section 4903.8(d) invalid. The WCAB, however, found that the declarant, Ilona Kulikova, possessed sufficient personal knowledge and access to information to competently testify regarding the services provided and billing accuracy. Consequently, the WCAB rescinded the WCJ's Findings and Orders and substituted new findings declaring the lien claimants' original section 4903.8(d) declarations valid, thus remanding the matter for further proceedings.

Labor Code Section 4903.8(d)Lien claimantsDeclarationsCompetent to testifyPrima facie evidenceBurden of proofIndustrial Healthcare PMGComplete InterpretingPeralta Hills-Mission Valley ImagingIlona Kulikova
References
Case No. ADJ8182087
Regular
Jan 18, 2018

Darin Day vs. CITY OF LOS ANGELES, TRISTAR

The Workers' Compensation Appeals Board affirmed a prior decision allowing a medical lien by VQ Orthocare against the City of Los Angeles. The Board found VQ's lien was valid despite late filing of a required declaration, as the lien was filed before the relevant statute's effective date. Defendant's arguments regarding the timeliness and form of the declaration were rejected, with the Board noting compliance with procedural rules for electronic filing and declarations under penalty of perjury. The lien was thus permitted to proceed on its merits.

Labor Code section 4903.8(d)Declaration requirementLien validityStatute of limitationsReconsiderationFindings and OrderMedical treatment lienSB 863SB 1160Declaration of readiness
References
Case No. ADJ3425275 (VNO0499477)
Regular
Oct 18, 2018

KAREN JACOBSEN vs. KRISTIN MULHALL, AMERICAN HOME ASSURANCE COMPANY, Administered by AIG

This case concerns a medical treatment lien filed before January 1, 2013, by the Long Beach Pain Center. The defendant argued the lien should be dismissed for failure to timely file a sworn declaration under Labor Code section 4903.8(d) and for alleged ownership by a "suspended provider." The Board affirmed the WCJ's decision, finding the declaration defect curable and the defendant failed to prove ownership/control under section 139.21. However, the Board noted the untimeliness of the declaration and directed the WCJ to consider sanctions.

RemittiturPetition for Writ of ReviewPetition for ReconsiderationSupplemental Findings of Fact and OrdersLien ClaimantMedical Treatment LienLabor Code Section 4903.8(d)Sworn DeclarationDismissed by Operation of LawLabor Code Section 139.21
References
Case No. ADJ8324040
Regular
Mar 15, 2019

ISAIAS GARCIA vs. CERADYNE, INC.; XL INSURANCE c/o SEDGWICK CLAIMS MANAGEMENT SERVICE

The Workers' Compensation Appeals Board granted reconsideration to lien claimants Technical Surgical Support and Comprehensive Outpatient Surgery Center. The WCJ had disallowed their liens because their Labor Code section 4903.8(d) declarations were filed untimely and not considered part of the record. The Board found that while the declarations were indeed filed late, the liens themselves were filed before January 1, 2013, predating a stricter WCAB rule. The Board rescinded the WCJ's order, returning the case for further proceedings to allow the defendant to examine the declarant and for a merits-based consideration of the liens.

Labor Code section 4903.8(d)lien claimantsPetition for ReconsiderationFindings and OrderWCJDeclaration of Readinesslien hearinguntimely declarationWCAB Rule 10770(c)(8)Mendoza v. Oak Grove
References
Case No. ADJ7580462; ADJ7580463; ADJ8813744
Regular
Mar 11, 2025

DORINA CORNEJO vs. SEARS HOLDINGS CORPORATION, ACE AMERICAN INSURANCE COMPANY

Lien claimant Supreme Copy Service, Inc., sought reconsideration of a workers' compensation administrative law judge's (WCJ) findings regarding its withdrawn lien and sanctionable conduct. The Workers' Compensation Appeals Board (WCAB) granted the petition for reconsideration, rescinding the previous findings. The Board determined that the lien was dismissed by operation of law on July 3, 2017, due to the lien claimant's failure to file a required declaration under Labor Code section 4903.05. Consequently, the defendant's petition for sanctions was rendered moot, as the WCAB no longer had jurisdiction over the dismissed lien.

Workers Compensation Appeals BoardLien ClaimantPetition for ReconsiderationFindings of FactSanctionable ConductLabor Code Section 4903.05Dismissal by Operation of LawDeclaration Pursuant to Labor Code Section 4903.8Declaration Pursuant to Labor Code Section 4903.05(c)(3)Electronic Adjudication Management System
References
Case No. ADJ8396919
Regular
Jan 26, 2016

LEONEL ENCISO SANTOS vs. RCR PLUMBING MECHANICAL, ARCH INSURANCE SERVICES, GALLAGHER BASSETT SERVICES, INC.

This case involves petitions to dismiss liens based on untimely declarations required by Labor Code section 4903.8(d). The Appeals Board affirmed the trial judge's denial of dismissal, finding the statute does not mandate dismissal for pre-2013 liens filed untimely. However, the Board amended the findings to formally admit Foundation's corrected declaration and remanded for the WCJ to consider sanctions against the lien claimants for their delays.

Labor Code section 4903.8(d)Lien claimsPetition to dismissTimeliness of declarationReconsiderationFindings and OrderAmended declarationNatural personCompetent witnessPersonal knowledge
References
Case No. ADJ10293666
Regular
Feb 20, 2020

LUIS MEJIA vs. TRI COAST BUILDERS, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board (WCAB) granted reconsideration to address the validity of Dental Trauma Center's lien. Dental Trauma Center initially filed a lien with an unsigned Labor Code section 4903.8(d) declaration, which is invalid under the statute. Subsequently, they filed a signed declaration, but the WCAB determined this did not cure the original defect and was untimely. Therefore, the WCAB rescinded the prior order allowing the lien to be heard on its merits and dismissed the lien as invalid by operation of law.

Labor Code section 4903.8Lien invalidityDeclaration of readinessEquitable principlesDismissal by operation of lawTimely filingUnsigned declarationCuring defectsMerits hearingReconsideration
References
Case No. ADJ7133410
Regular
Dec 10, 2018

HUGO DIAZ vs. YOUTH CONNECTION OF VENTURA COUNTY, REDWOOD FIRE & CASUALTY COMPANY

The Workers' Compensation Appeals Board granted reconsideration, rescinded a prior order, and returned the case for further proceedings. The administrative law judge had dismissed a lien claimant's lien for failing to timely file a declaration under Labor Code section 4903.8. However, the Board found that section 4903.8, as amended, does not mandate dismissal for pre-2013 liens with untimely declarations. While the lien is not dismissed, the Board noted that the untimely filing could be grounds for sanctions under Labor Code section 5813.

Workers' Compensation Appeals BoardLien claimantPetition for ReconsiderationFindings and OrderLabor Code section 4903.8Mandatory dismissalSenate Bill 863Declaration of perjuryUntimely declarationInvalid lien
References
Showing 1-10 of 1,156 results

Ready to streamline your practice?

Apply these legal strategies instantly. CompFox helps you find decisions, analyze reports, and draft pleadings in minutes.

CompFox Logo

The AI standard for workers' compensation professionals. Faster research, deeper analysis, better outcomes.

Product

  • Platform
  • Workflow
  • Features
  • Pricing

Solutions

  • Defense Firms
  • Applicants' Attorneys
  • Insurance carriers
  • Medical Providers

Company

  • About
  • Insights
  • Case Law

Legal

  • Privacy
  • Terms
  • Trust
  • Cookies
  • Subscription

© 2026 CompFox Inc. All rights reserved.

Systems Operational