OSCAR DE LEON vs. KOHLS BUILDING MAINTENANCE, LIBERTY MUTUAL INSURANCE
The Workers' Compensation Appeals Board granted reconsideration for four lien claimants who were denied due process. The WCJ had issued Orders to Pay, purporting to fully satisfy lien claims, without conducting a trial because the applicant was absent. The Board held that lien claimants are entitled to a trial to present evidence and make a record, regardless of applicant attendance. Therefore, the Orders to Pay were rescinded and the case returned for further proceedings and a new decision, including potential lien trials.