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

Case No. ADJ6699348
Regular
Mar 17, 2016

KANON MONKIEWICZ vs. RM STORE FIXTURES, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board (WCAB) issued a Notice of Intention to find that Labor Code section 4903.8(a) does not preclude awards to lien claimants Rx Funding Solutions, LLC and PharmaFinance, LLC. This is because the 2014 amendments to section 4903.8(a)(2) specify that it does not apply to assignments completed prior to January 1, 2013. Both of the lien claimants' assignments were made before this date, thus exempting them from the preclusion. The WCAB is amending its previous order and returning the case to the trial level for further proceedings on the merits of the liens.

Labor Code 4903.8Lien claimantsAssignment of receivablesCessation of businessPharmacy lienMedical lienSB 863AB 2732Prospective vs. retrospective applicationWCAB rules
References
10
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The Workers' Compensation Appeals Board granted reconsideration, rescinded a prior order, and returned the case for further proceedings.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
3
Case No. ADJ4140574 (VNO 0417628) ADJ3588068 (VNO 0472981)
Regular
Jun 03, 2013

KEVIN THOMPSON vs. COUNTY OF LOS ANGELES, TRISTAR RISK MANAGEMENT

The Workers' Compensation Appeals Board awarded applicant Kevin Thompson an additional attorney's fee of $1,500 under Labor Code section 5801. This fee is for services rendered by his attorney in successfully defending against the defendant's petition for writ of review to the Court of Appeal. The Board disallowed the requested clerical fees as section 5801 applies only to attorney services. Additionally, the request for costs under Labor Code section 5811 was denied due to the lack of required itemization and supporting documentation.

Labor Code § 5801Attorney's feePetition for Writ of ReviewAppeals BoardSupplemental awardReasonable attorney's feeAppellate levelPenaltyClerical servicesLabor Code § 5811
References
12
Case No. MISSING
Regular Panel Decision

In Re Pursuant to Section 304 of the Bankruptcy Code of Banco Nacional De Obras Y Servicios Publicos, S.N.C.

The International Association of Machinists and Aerospace Workers (IAM) sought relief from a preliminary injunction to pursue an action against Aeronaves de Mexico, S.A. de C.V. (Aeronaves) for declaratory judgment concerning a collective bargaining agreement. Aeronaves, represented by its Mexican bankruptcy trustee Banobras, objected, arguing the claims should be handled in Mexican bankruptcy court. Judge Tina L. Brozman analyzed the request in the context of section 304 of the Bankruptcy Code, emphasizing the specialized nature of American labor law, particularly the Railway Labor Act (RLA). Balancing international comity with the protection of American creditors, the court found that the issues regarding the existence and terms of the collective bargaining agreement required the expertise of an American district court. Therefore, the motion for relief from the stay was granted to permit the IAM action to proceed in the Southern District of New York.

Bankruptcy LawInternational ComitySection 304 StayRailway Labor Act (RLA)Collective Bargaining AgreementForeign BankruptcyAncillary ProceedingsDeclaratory ReliefLabor DisputeCreditor Claims
References
32
Case No. ADJ1474695
Regular
Apr 12, 2019

IRIS TABORA vs. HARBOR BUILDING SERVICES, STATE COMPENSATION INSURANCE FUND

This case concerns lien claimants whose liens were filed before January 1, 2013. The WCJ initially invalidated their liens for failing to submit declarations under Labor Code section 4903.8(d). However, the Appeals Board rescinded this order, finding that section 4903.8(e) does not apply to pre-2013 liens. The matter was returned to the trial level to allow the lien claimants to submit compliant declarations and for further proceedings.

Workers' Compensation Appeals BoardLabor Code Section 4903.8Lien ClaimantsDeclarationReconsiderationMinute OrderWCJInvalid LiensSubstantial JusticeCompromise and Release
References
2
Case No. ADJ66 99348
Regular
Apr 11, 2016

KANON MONKIEWICZ vs. RM STORE FIXTURES, STATE COMPENSATION INSURANCE FUND

This case involves lien claimants Rx Funding Solutions and PharmaFinance seeking payment for assigned medical expenses. The Workers' Compensation Appeals Board (WCAB) reconsidered a prior ruling that disallowed these liens under Labor Code section 4903.8(a). The WCAB found that the 2014 amendments to section 4903.8(a)(2) specifically exempt assignments made before January 1, 2013, from preclusion. Therefore, the WCAB amended the prior order to allow the lien claimants to proceed with further proceedings on the merits of their claims.

WCABReconsiderationLien ClaimantsLabor Code Section 4903.8AssignmentCeased Doing BusinessPharmacyPharmacistSB 863AB 2732
References
10
Case No. ADJ9063212
Regular
Feb 15, 2019

LUIS VILLAGOMEZ vs. WALMART STORES, INC.; ACE AMERICAN, administered by YORK

This Workers' Compensation Appeals Board case involved liens filed by Mesa Pharmacy and ResHealth Medical, which were deemed invalid by the WCJ under Labor Code section 4903.8(e). Lien claimants sought reconsideration, arguing the WCJ incorrectly placed the burden of proof regarding declarant competency on them. The Appeals Board rescinded the WCJ's decision and returned the case for further proceedings. The Board clarified that declarants under section 4903.8(d) must have personal knowledge of the services provided and billing accuracy. It also noted that all submitted declarations, not just one, should be considered when evaluating compliance with the statute.

Labor Code section 4903.8(e)declarant competencypersonal knowledgehearsaypenalty of perjurylien validityworkers' compensation liensassignment violationreconsiderationFindings of Fact and Order
References
2
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
11
Case No. ADJ122717
Regular
Dec 13, 2012

JOE MARTINEZ vs. CDC-CORCORAN STATE PRISON, STATE COMPENSATION INSURANCE FUND

Here is a summary of the case in four sentences: The Workers' Compensation Appeals Board denied a lien claim by the CCPOA Benefits Trust Fund for over $42,000 paid to applicant Joe Martinez for living expenses. The Board found no statutory authority under Labor Code sections 4903 or 4903.1 to allow reimbursement for living expenses paid by a self-insured employee welfare benefit plan. Specifically, Labor Code section 4903.1(a)(3) only permits such liens for group disability policies under specific conditions not met here. The Board affirmed the trial judge's decision disallowing the lien.

Workers' Compensation Appeals BoardLien claimLabor Code section 4903(c)Living expensesSelf-insured employee welfare benefit planStatutory authorizationReimbursementPermanent disabilityTemporary disabilityGroup disability policy
References
8
Case No. ADJ3550549 (LAO 0884192)
Regular
Sep 22, 2016

JACK DUPONT (Dec'd), ANYAWAN DUPONT (Widow) vs. C.R. ENGLAND, INC.; XL SPECIALTY INSURANCE COMPANY, administered by BROADSPIRE

This case involves a remand from the Court of Appeals to the Workers' Compensation Appeals Board (WCAB) for the purpose of awarding attorney's fees and costs under Labor Code Section 5801. Applicant's attorney and the defendant's attorney jointly stipulated to an award of $11,600.00 to resolve this issue. The WCAB approved this stipulation and returned the matter to the trial level.

Labor Code section 5801attorney's feesWorkers' Compensation Appeals Boardremandedstipulationapplicant's attorneydefendant's attorneyjoint lettertrial levelaward
References
0
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