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

Case No. 2007 NY Slip Op 32865(U)
Regular Panel Decision

Pomahac v. TrizecHahn 1065 Avenue of the Americas, LLC

The plaintiff slipped and fell in a building lobby due to a wet floor and subsequently sued the building manager (TrizecHahn) and maintenance company (ABM) for negligence, alleging a failure to place sufficient mats. Defendants moved for summary judgment, arguing they took reasonable precautions by deploying two mats, a caution sign, and having an employee mop. The Supreme Court initially denied the defendants' motions on reargument. However, the appellate court reversed, granting summary judgment to the defendants, stating their actions constituted reasonable precautions as a matter of law. The court also held that failure to adhere to an internal policy for mat placement does not automatically equate to negligence if that policy's standard exceeds reasonable care. A dissenting opinion argued that a triable issue of fact existed concerning the reasonableness of precautions given recurring hazardous conditions and insufficient mat coverage.

Summary JudgmentNegligencePremises LiabilityWet FloorBuilding MaintenanceReasonable Care StandardInternal PolicySlip and FallTerrazzo FloorAppellate Division
References
24
Case No. ADJ1634986
Regular
Sep 10, 2013

REGINA CAMACHO vs. RIO SCHOOL DISTRICT, YORK INSURANCE SERVICES

This Workers' Compensation Appeals Board decision denies a lien claimant's petition for reconsideration. The lien claimant, Pueblo Surgery Center, failed to meet its burden of proof to establish the reasonableness of its $18,940.00 surgical charges. The Board adopted the WCJ's reasoning that Pueblo's submitted exhibits lacked necessary substantiation and were insufficient to prove their charges were reasonable. Therefore, the denial of reconsideration stands, upholding the original determination regarding the lien claim.

Workers' Compensation Appeals BoardPetition for ReconsiderationLien ClaimantReasonableness of ChargesOutpatient Surgery CenterBillingDeclarations Under Penalty of PerjuryComparative BillingBurden of ProofIndependent Bill Review
References
4
Case No. ADJ1220602 (SJO 0264607)
Regular
Sep 08, 2009

MARIA ISABEL RAMIREZ vs. QUIZNOS, STATE FARM 21567 BAKERSFIELD

The Workers' Compensation Appeals Board granted reconsideration to address the defendant's challenge to a $\$1,570$ lien for interpreting services. While agreeing interpreters are reasonably required for non-English speaking injured workers, the Board found Ditto Interpreting failed to adequately prove the reasonableness of its fees. Specifically, Ditto billed for dates not coinciding with medical evaluations and provided insufficient evidence of the reasonableness of its charges compared to other cases. The case was returned to the trial level for further proceedings on these issues.

Workers' Compensation Appeals BoardQUIZNOSSTATE FARMMARIA ISABEL RAMIREZDitto InterpretingLien ClaimReconsiderationFindings and AwardStipulated AwardCompromise & Release
References
1
Case No. ADJ3172767
Regular
May 10, 2017

VICTOR GONZALEZ vs. CITISTAFF SOLUTIONS, STATE COMPENSATION INSURANCE FUND

The Appeals Board affirmed the WCJ's decision finding the lien claimant, Monrovia Memorial Hospital, was entitled to nothing for its services. The WCJ properly excluded the lien claimant's expert declaration as it was submitted after discovery closed. The lien claimant failed to meet its burden of proving its charges were reasonable and based on a reasonable cost basis, as required by precedent in cases exempt from the Official Medical Fee Schedule. Mere presentation of usual and customary charges, without evidence of reasonableness or comparability, is insufficient.

Workers' Compensation Appeals BoardVictor GonzalezCitistaff SolutionsState Compensation Insurance FundMonrovia Memorial Hospitallien claimantbill review expertdue processreasonableness of chargesOMFS exemption
References
2
Case No. ADJ6884625
Regular
Jun 19, 2012

JASON PETERSON, KIRSTIE MCCRAINE-PETERSON vs. CALIFORNIA DEPARTMENT OF CORRECTIONS AND REHABILITATION, STATE COMPENSATION INSURANCE FUND

This case concerns the death of Jason Peterson, a correctional officer, from a pulmonary embolism after injuring his calf in a kickboxing class. The applicant, his widow, claimed the injury and death were work-related, arguing the kickboxing class was a reasonable expectancy of employment due to a general fitness requirement and incentive program. The Workers' Compensation Appeals Board (WCAB) affirmed the WCJ's decision, finding the claim barred by Labor Code Section 3600(a)(9) because the decedent's belief that kickboxing was required was not objectively reasonable, as mere general assertions of fitness expectations are insufficient. Commissioner Brass dissented, believing the decedent's participation was both subjectively and objectively reasonable given its likely benefit to his job performance as a correctional officer.

Labor Code Section 3600(a)(9)Pulmonary EmbolismCorrectional OfficerKickboxingOff-duty Recreational ActivityReasonable Expectancy of EmploymentSubjective BeliefObjective ReasonablenessEzzy testCity of Stockton v. Workers' Comp. Appeals Bd. (Jenneiahn)
References
2
Case No. MISSING
Regular Panel Decision

People v. McGinnis

This case involves the defendant, Felicia McGinnis, who moved to dismiss a charge of loitering for the purpose of engaging in prostitution (Penal Law § 240.37 [2]) due to facial insufficiency of the accusatory instrument. The court examined the complaint and supporting deposition, noting the reliance on a preprinted, check-off form that vaguely alleged the defendant loitered, spoke to three passersby for 20 minutes, and was previously arrested for prostitution-related offenses in an area frequented by prostitutes. The court found the allegations lacked specific, overt acts demonstrating a clear intent to solicit prostitution. It concluded that the general description of her clothing, ambiguous statement, and officer's prior experience were insufficient to establish reasonable cause. The motion to dismiss the accusatory instrument for facial insufficiency was therefore granted.

LoiteringProstitutionFacial InsufficiencyAccusatory InstrumentCriminal Procedure LawPenal LawSufficiency of EvidenceSupporting DepositionCheck-off FormsEvidentiary Character
References
13
Case No. 2007 NY Slip Op 30531(U)
Regular Panel Decision
Apr 05, 2007

Schirmer v. Athena-Liberty Lofts, LP

This case is an appeal from an Order of the Supreme Court, New York County, regarding a personal injury action. The plaintiff, a worker at a construction site, sustained injuries, leading to the site owner, Lofts, settling the claim after being found liable under Labor Law § 240 (1). Lofts then pursued indemnity claims against lighting contractor HP and the plaintiff's employer, Burgess. The Appellate Court modified the lower court's decision, vacating the finding that Lofts' settlement amount was reasonable due to Lofts' failure to properly demonstrate reasonableness and its mischaracterization of waiver arguments by HP and Burgess. The Court also affirmed the denial of HP's motion for summary judgment, citing unresolved factual issues concerning inadequate lighting as a cause of the accident.

Personal InjuryConstruction Site AccidentSummary JudgmentIndemnity ClaimLabor Law § 240(1)Appellate DivisionThird-Party ActionSettlement ReasonablenessCross ClaimsInadequate Lighting
References
4
Case No. BAK 0139905
Regular
Dec 21, 2007

JOSE DE JESUS ZEPEDA (JOSE DE JESUS ZEPEDA MARTINEZ) vs. ARTS CUSTOM CABINETS, AACA/AMERICAN COMMERCIAL CLAIMS MANAGEMENT

The Workers' Compensation Appeals Board granted reconsideration of a Findings and Award concerning lien claimant's facility fees. The Board found the record insufficient to determine if the discogram and discectomy were reasonable and necessary treatments for the applicant's industrial injury. The case is returned to the trial level for further development of the medical record, including addressing ACOEM guidelines and the reasonableness of surgical center fees.

Lien claimantReconsiderationFindings and AwardFacility feesEpidural injectionsDiscogramDiscectomyHerniated nucleus pulposusReasonable and necessaryMedical evidence
References
6
Case No. ADJ3963036 (LAO 0785173) ADJ1393538 (LAO 0785174) ADJ3452060 (LBO 0369501)
Regular
Oct 03, 2008

JULIANA SANCHEZ vs. HUNTINGTON MEMORIAL HOSPITAL

This case concerns a workers' compensation lien filed by SB Surgery Center for $\$21,124.64$ related to applicant's shoulder surgery. The Appeals Board affirmed the lower ruling disallowing the majority of the lien because SB failed to prove its charges were reasonable, not just that the defendant paid a lesser amount. The Board clarified that lien claimants bear the burden of proving reasonableness and that their own billing alone is insufficient evidence.

Workers' Compensation Appeals BoardSB Surgery Centerlien claimantreconsiderationKunzTapiareasonableness of chargesburden of proofoutpatient surgery center servicesJoint Findings & Order
References
2
Case No. LAO 835734
Regular
Nov 19, 2007

MARINA SANCHEZ vs. KEELING PROPERTY, THE ZENITH INSURANCE COMPANY

The Appeals Board granted reconsideration and rescinded the WCJ's decision, finding insufficient evidence to support the award for the lien claimant's services. The Board determined that the WCJ failed to address whether the medical treatment was reasonably required and that neither party presented sufficient evidence regarding the reasonableness of the facility fees according to *Kunz* guidelines. The case was returned to the trial level for further proceedings to develop the record on these issues and for a new decision.

Wilshire Surgical CenterKeeling PropertyZenith Insurance CompanyMarina SanchezKunz v. Patterson Floor CoveringFindings and AwardPetition for Reconsiderationusual and customary feesoutpatient surgery facility feesreasonableness of charges
References
9
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