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Case Law Database

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

Case No. SBR 0315782
Regular
Jul 30, 2007

GORDON ADAMS vs. SOUTHLAND DRYWALL COMPANY, STATE COMPENSATION INSURANCE FUND

This case concerns a lien claimant, Premier Outpatient Surgery Center, Inc., whose lien was denied because it allegedly did not use its full corporate name or have a fictitious business name permit. The Appeals Board rescinded the denial and returned the case for further proceedings, finding that Premier was properly licensed as an outpatient facility and that the defendant did not timely raise the fictitious business name statement issue. The Board clarified that a facility fee lien claimant is not required to have a Medical Board fictitious-name permit, but may need to file a fictitious business name statement if operating under a name other than its legal corporate name.

Workers Compensation Appeals BoardLien ClaimantFictitious Business Name StatementFictitious-Name PermitBusiness & Professions Code Section 17910Business & Professions Code Section 2415(a)Medical Board of CaliforniaOutpatient SettingFacility FeeCompromise and Release
References
13
Case No. LAO 0878674
Regular
Mar 06, 2008

KARLA BUENO vs. PLAZA DEFENDANT LA RAZA, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board (WCAB) granted reconsideration of a decision that barred a lien claim due to the alleged lack of a fictitious business name permit. The WCAB found that while the lien claimant presented a surgical clinic license, the record was unclear about its actual business name and compliance with fictitious name filing requirements. The case is remanded for further proceedings to determine the lien claimant's true name and establish its compliance with fictitious business name laws.

Fictitious Business Name StatementSurgical Clinic LicenseHealth ServicesBusiness and Professions CodeMedical BoardLien ClaimantOutpatient SettingAdministrative Law JudgeReconsiderationReasonableness of Fees
References
14
Case No. STK 0189570
Regular
Jul 30, 2007

JOSEPH BUENO vs. AMERICAN FIRE SYSTEMS, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board affirmed the administrative law judge's decision, allowing a lien claim of $10,838.43 for facility fees. The defendant argued the lien should be disallowed due to the lien claimant's alleged lack of a fictitious name permit. However, the Board found the lien claimant met its burden of proof by demonstrating proper licensure and that it was not operating under a fictitious name, thus not requiring a fictitious name permit from the Medical Board.

Workers Compensation Appeals BoardLien claimantFictitious name permitMedical Board of CaliforniaFacility feesArthroscopic surgeryStipulated awardPermanent disabilityFuture medical treatmentAmbulatory surgical centers
References
2
Case No. RIV 0037205, RIV 0070473
Regular
Jul 24, 2007

LORRIE AVERETTE vs. STATE OF CALIFORNIA, DEPARTMENT OF SOCIAL SERVICES, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board affirmed a prior ruling that Premier Outpatient Surgery Center was properly licensed and not required to have a fictitious name permit for services rendered. The defendant argued Premier lacked proper licensure and a fictitious name permit, but the Board found Premier met its burden of proof by submitting evidence of its licensure and accreditation. Premier was determined to be an "outpatient setting" rather than a "clinic," thus not requiring a fictitious name permit from the Medical Board.

Workers' Compensation Appeals BoardLien claimantFictitious name permitMedical Board of CaliforniaOutpatient surgery servicesLicensureAccreditationAmbulatory surgical centersZenith Ins. Co. v. Workers' Comp. Appeals Bd. (Capi)Stokes v. Patton State Hospital
References
2
Case No. RIV 0047694, RIV 0063415 RIV 0063416, RIV 0063417
Regular
Jul 19, 2007

DEADRA FRANKLIN vs. STATE OF CALIFORNIA / DEPARTMENT OF MENTAL HEALTH / PATTON STATE HOSPITAL, legally uninsured, adjusted by STATE COMPENSATION INSURANCE FUND

This case concerns a lien claim by Premier Outpatient Surgery Center for unpaid services. The WCAB rescinded a previous order disallowing the lien due to Premier's lack of a fictitious-name permit, finding that the distinction between providing medical treatment versus an "outpatient setting" was not adequately addressed. The matter is returned to the trial level to determine if Premier, as an outpatient facility, was required to obtain a fictitious-name permit from the Medical Board.

Workers' Compensation Appeals BoardPremier Outpatient Surgery Centerfictitious-name permitBusiness and Professions CodeMedical Boardlien claimantoutpatient facilitycliniclicensureaccreditation
References
2
Case No. ANA 0357324
Regular
Aug 20, 2007

ANDRES QUINONES vs. AN'S WORLD SERVICE INC., STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board granted SCIF's petition for removal to reconsider a prior order regarding a lien claimant's (LC) right to payment. SCIF argued LC lacked standing because it failed to prove it held a required fictitious name permit from the Medical Board, while LC contended it was an "outpatient setting" exempt from such a permit. The Board rescinded the original order and returned the case for the WCJ to determine if LC is an "outpatient setting" or a "clinic" to assess its compliance with licensing and fictitious name requirements.

Workers' Compensation Appeals BoardRemovalLien ClaimantFictitious Name PermitMedical BoardOutpatient SettingClinicLicensureBusiness and Professions CodeStokes v. Patton State Hospital
References
1
Case No. ANA 381864
Regular
Feb 25, 2008

TUAN KHANH DO vs. CONEYBEARE PERSONNEL SERVICES, STATE COMPENSATION INSURANCE FUND

This case concerns a Qualified Medical Examiner's (QME) entitlement to payment for medical-legal services. The defendant insurer argued that the QME's lien claim was invalid due to the use of a business name without a fictitious business name permit. However, the Workers' Compensation Appeals Board denied reconsideration, finding the QME rendered services and signed reports under his own name. The Board further noted that the insurer failed to properly object to the billings within the regulatory timeframe and the lien claim form was amended to reflect the QME's individual name.

WCABState Compensation Insurance FundMedical-legal servicesFictitious business name permitQualified Medical ExaminerLien claimCompromise and releaseMedical Board of CaliforniaBusiness and Professions CodeLabor Code
References
0
Case No. MISSING
Regular Panel Decision
Aug 31, 1999

Daniello v. Holy Name Church

The plaintiff, an employee of Kings Harbor Care Center, suffered injuries after slipping from an extension ladder while painting a school gym owned by Holy Name Church, for which he received workers' compensation benefits. He subsequently sued Holy Name Church under Labor Law § 240 (1) for failing to provide safety devices, and Holy Name brought a third-party action against Kings for indemnification and contribution. The trial court improperly granted summary judgment on liability to the plaintiff and the third-party plaintiff on oral applications without evidentiary support, contrary to CPLR 3212 (b). The Supreme Court, Appellate Division, reversed the judgment, vacated it, and remanded the matter for a new trial on all issues due to the procedural error. Additionally, the court affirmed that the plaintiff was not a "volunteer" outside the protection of Labor Law § 240 (1), as he was a paid employee directed to perform the work.

Labor Law 240(1)Ladder FallWorkplace AccidentSummary JudgmentEvidentiary StandardsVolunteer StatusIndemnification ClaimContribution ClaimWorkers' Compensation BenefitsNew Trial Order
References
8
Case No. MISSING
Regular Panel Decision

Bessa v. Anflo Industries, Inc.

This case addresses motions for reargument filed by Royal One Real Estate, LLC and Vista Engineering Corporation, seeking dismissal of a plaintiff's negligence and Labor Law complaint. The plaintiff, Daniel Ribeiro, also known as Jordano Bessa, sustained injuries after falling into a hole at a construction storage yard. Defendants argued that the plaintiff committed fraud by using a fictitious name, which should bar his action. The court granted reargument but ultimately denied the motions to dismiss, holding that the plaintiff's use of an assumed identity did not prejudice the defendants nor negate the protections afforded to all employees under the Labor Law, irrespective of immigration status or name. The decision reaffirms that Labor Law protections apply broadly to all workers, and a dangerous work site condition claim is not affected by the name an employee uses.

NegligenceLabor LawPersonal InjuryReargumentSummary JudgmentFraudFictitious NameAssumed IdentityUndocumented WorkerWorkplace Safety
References
24
Case No. MON 0248414 MON 0331722
Regular
Jul 14, 2008

SANDRA WHIGHAM vs. CHIPTON-ROSS, ZURICH AMERICAN INSURANCE COMPANY

The Workers' Compensation Appeals Board (WCAB) reconsidered a lien claim denial based on a licensing name discrepancy. The WCAB rescinded the denial, finding that the lien claimant should have an opportunity to prove its licensing or fictitious business name compliance. The case is returned for further proceedings to determine the reasonableness of the lien claimant's charges.

Lien claimantSB Surgery CenterWCJFindings and OrderPetition for reconsiderationCompromise and ReleaseFictitious nameBusiness and Professions Code § 17910Medical BoardReasonableness of charges
References
5
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