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Case Law Database

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

Case No. ADJ9921643

Regular

Jul 09, 2019

Katherine Turner vs. CITY OF CULVER CITY

The Workers' Compensation Appeals Board granted reconsideration of a decision that deemed lien claims invalid due to electronic signatures on declarations. The Board found that electronic signatures, specifically the "S signature" format used in electronic filings, are legally sufficient under the Uniform Electronic Transactions Act. Consequently, the prior decision invalidating the liens based on the lack of a "wet" signature was rescinded, and the case was returned for further proceedings. The Board clarified that electronic signatures satisfy the requirements of Labor Code section 4903.8(d) declarations.

Labor Code section 4903.8(d)electronic signaturewet signaturepenalty of perjurylien claimantWorkers' Compensation Appeals BoardOpinion and Order Granting Petition for Reconsiderationfindings of fact and ordersadministrative law judgeUniform Electronic Transactions Act (UETA)

References

Case No. ADJ9169097 (MF) ADJ9165067

Regular

Aug 09, 2019

Rosa Reyes vs. Nestle USA, ACE American Insurance

This case involved lien claimants whose liens were disallowed because their Labor Code section 4903.8(d) declarations were signed with electronic "S" signatures rather than wet signatures. The Workers' Compensation Appeals Board (WCAB) granted reconsideration, holding that electronic signatures are valid for these declarations. The WCAB found that existing law and prior panel decisions support the use of electronic signatures, aligning with the Uniform Electronic Transactions Act. The matter was returned to the trial level for further proceedings consistent with this ruling.

Labor Code section 4903.8(d)wet signatureelectronic signaturelien claimantsJoint Findings of Fact and OrderElectronic Adjudication Management SystemJET File Business RulesEAMS Rulespenalty of perjuryUniform Electronic Transactions Act

References

Case No. ADJ9837116, ADJ9837115

Regular

Aug 10, 2018

EVERARDO OCAMPO SANCHEZ vs. MAJESTIC INTERIORS, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board (WCAB) rescinded a prior order dismissing a lien claimant's liens by operation of law. The WCAB found that a corporate signature on a Labor Code section 4903.05 declaration, when filed electronically, is permissible and does not necessarily render the declaration defective. The Board clarified that electronic signatures by entities are valid for these declarations, and the case was returned for a new decision on the validity of the declaration and other issues.

Workers' Compensation Appeals BoardLien ClaimLabor Code Section 4903.05DeclarationDismissal by Operation of LawElectronic SignatureJET FilerEAMSDigital SignatureUETA

References

Case No. ADJ10711762 ADJ10901794

Regular

Dec 24, 2019

DAVID YEREMYAN vs. COMFORT KEEPERS, INSURANCE COMPANY OF THE WEST

The Workers' Compensation Appeals Board granted reconsideration of a WCJ's decision that a lien claimant's Labor Code section 4903.8(d) declaration required a "wet signature" for validity. The Board found that an electronically signed declaration, submitted via JET filing, meets legal requirements and is attributable to the signatory. Therefore, the lien claimant's declaration was deemed validly filed on the date of electronic submission, not when the "wet signature" was later provided. The case was remanded to the trial level for further proceedings on the statute of limitations issue.

WCABPetition for ReconsiderationLien ClaimantLabor Code section 4903.8(d)Wet SignatureElectronic SignatureStatute of LimitationsEDEXISJET FilerEAMS

References

Case No. ADJ8930150

Regular

Jan 14, 2019

MARIA JUAN vs. PJ MEDICAL MANAGEMENT, INC., STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board granted a lien claimant's Petition for Removal, rescinding the WCJ's order requiring a wet signature on a Labor Code section 4903.8 declaration. The Board found that an electronic signature on the declaration was legally valid and sufficient under California law, despite not meeting EAMS filing requirements for unstructured documents. The Board clarified that a defect in filing procedure does not automatically invalidate the signature itself. Therefore, no correction was necessary as the document was accepted for filing.

WCABPetition for RemovalLien ClaimantLabor Code 4903.8DeclarationWet SignatureElectronic SignatureMedical-Legal ExpensesEAMSJET-filing

References

Case No. ADJ17371801; ADJ18218517

Regular

Oct 10, 2025

MARIO PALACIOS vs. PLAN B ADVANTAGE, INC.; STATE COMPENSATION INSURANCE FUND

Applicant Mario Palacios petitioned for removal from a WCJ's order mandating in-person appearances for himself and two witnesses to verify signatures on a Compromise and Release (C&R). He also sought clarification on electronic signatures and challenged a prior C&R disapproval. The Workers' Compensation Appeals Board granted the petition for removal, rescinding the August 4, 2025 order and allowing Palacios to appear remotely to verify his signature. The Board declined to issue an advisory opinion on electronic signatures but referenced relevant codes, and deemed the challenge to the prior C&R disapproval moot due to an amended C&R.

Petition for RemovalCompromise and ReleaseElectronic SignaturesIn-Person HearingRemote AppearanceDue ProcessWCJ OrderRescind OrderGood CauseWitness Testimony

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. ADJ3874707 (ANA 0393103)

Regular

Jul 01, 2009

WILLIAM MARCHESE vs. THE HOME DEPOT, Permissibly SelfInsured, Adjusted By SEDGWICH CLAIMS MANAGEMENT SERVICES, INC.

This case involves a worker's compensation claim where the applicant's former attorney, Krishna Gulaya, is facing potential sanctions. The Workers' Compensation Appeals Board (WCAB) is investigating allegations that Gulaya submitted a falsified Compromise and Release agreement, including improper witnessing and backdating of signatures. The WCAB has scheduled a conference solely to address the imposition of sanctions against Gulaya for this misconduct. Gulaya is ordered to appear at the conference to demonstrate good cause why sanctions should not be imposed.

Workers' Compensation Appeals BoardSanctionsApplicant's AttorneyCompromise and ReleaseWCJIndustrial InjuryFindings of FactAward and OrderSet AsideWitness Signatures

References

Case No. ADJ7484646

Regular

Apr 26, 2012

CHRISTINE SPIGNER vs. NEC ELECTRONICS, MITSUI SUMITOMO MARINE MANAGEMENT

The Workers' Compensation Appeals Board dismissed Christine Spigner's Petition for Reconsideration in the case against NEC Electronics and Mitsui Sumitomo Marine Management. The dismissal was based on the petition's failure to be verified, a violation of Labor Code section 5902. This procedural defect rendered the petition invalid. The Board's decision was consistent with established precedent regarding unverified petitions.

Petition for ReconsiderationVerifiedLabor Code section 5902DismissalWCJ ReportWorkers' Compensation Appeals BoardADJ7484646SpignerNEC ElectronicsMitsui Sumitomo Marine Management

References

Case No. ADJ8390531

Regular

Feb 21, 2018

SARA RUSH vs. PROCARE MOBILE RESPONSE, EVEREST NATIONAL INSURANCE COMPANY, administered by SEDGWICK CLAIMS MANAGEMENT SERVICES

This case concerns a medical treatment lien disallowance for non-compliance with Labor Code § 4903.8(d), which requires a declaration from a competent person attesting to services rendered and accurate billing. The Appeals Board rescinded the initial decision, finding that the lien claimant had substantially complied with the statute. The Board held that an electronic "S" signature was sufficient and that the billing clerk, Jennifer Zambrana, was competent to make the declaration given the circumstantial evidence of treatment. Consequently, the lien was not disallowed, and the case was returned for further proceedings.

WCABreconsiderationlien claimantdeclarationsection 4903.8(d)billing statementcostssanctionsJennifer Zambranacompetent witness

References

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Updated Daily

Case Law Database

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

Case No. ADJ9921643

Regular

Jul 09, 2019

Katherine Turner vs. CITY OF CULVER CITY

References

Case No. ADJ9169097 (MF) ADJ9165067

Regular

Aug 09, 2019

Rosa Reyes vs. Nestle USA, ACE American Insurance

References

Case No. ADJ9837116, ADJ9837115

Regular

Aug 10, 2018

EVERARDO OCAMPO SANCHEZ vs. MAJESTIC INTERIORS, STATE COMPENSATION INSURANCE FUND

Workers' Compensation Appeals BoardLien ClaimLabor Code Section 4903.05DeclarationDismissal by Operation of LawElectronic SignatureJET FilerEAMSDigital SignatureUETA

References

Case No. ADJ10711762 ADJ10901794

Regular

Dec 24, 2019

DAVID YEREMYAN vs. COMFORT KEEPERS, INSURANCE COMPANY OF THE WEST

WCABPetition for ReconsiderationLien ClaimantLabor Code section 4903.8(d)Wet SignatureElectronic SignatureStatute of LimitationsEDEXISJET FilerEAMS

References

Case No. ADJ8930150

Regular

Jan 14, 2019

MARIA JUAN vs. PJ MEDICAL MANAGEMENT, INC., STATE COMPENSATION INSURANCE FUND

WCABPetition for RemovalLien ClaimantLabor Code 4903.8DeclarationWet SignatureElectronic SignatureMedical-Legal ExpensesEAMSJET-filing

References

Case No. ADJ17371801; ADJ18218517

Regular

Oct 10, 2025

MARIO PALACIOS vs. PLAN B ADVANTAGE, INC.; STATE COMPENSATION INSURANCE FUND

Petition for RemovalCompromise and ReleaseElectronic SignaturesIn-Person HearingRemote AppearanceDue ProcessWCJ OrderRescind OrderGood CauseWitness Testimony

References

Case No. ADJ8182087

Regular

Jan 18, 2018

Darin Day vs. CITY OF LOS ANGELES, TRISTAR

Labor Code section 4903.8(d)Declaration requirementLien validityStatute of limitationsReconsiderationFindings and OrderMedical treatment lienSB 863SB 1160Declaration of readiness

References

Case No. ADJ3874707 (ANA 0393103)

Regular

Jul 01, 2009

WILLIAM MARCHESE vs. THE HOME DEPOT, Permissibly SelfInsured, Adjusted By SEDGWICH CLAIMS MANAGEMENT SERVICES, INC.

Workers' Compensation Appeals BoardSanctionsApplicant's AttorneyCompromise and ReleaseWCJIndustrial InjuryFindings of FactAward and OrderSet AsideWitness Signatures

References

Case No. ADJ7484646

Regular

Apr 26, 2012

CHRISTINE SPIGNER vs. NEC ELECTRONICS, MITSUI SUMITOMO MARINE MANAGEMENT

Petition for ReconsiderationVerifiedLabor Code section 5902DismissalWCJ ReportWorkers' Compensation Appeals BoardADJ7484646SpignerNEC ElectronicsMitsui Sumitomo Marine Management

References

Case No. ADJ8390531

Regular

Feb 21, 2018

SARA RUSH vs. PROCARE MOBILE RESPONSE, EVEREST NATIONAL INSURANCE COMPANY, administered by SEDGWICK CLAIMS MANAGEMENT SERVICES

WCABreconsiderationlien claimantdeclarationsection 4903.8(d)billing statementcostssanctionsJennifer Zambranacompetent witness

References

Showing 1-10 of 729 results

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