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

Case No. ADJ1700793 (SAC 0307437) ADJ3714832 (SAC 0307399)
Regular
Jun 13, 2011

JUANITA BRADLEY (Deceased) vs. COUNTY OF PLACER

This case involves a dispute over liability for a medical-legal report cost. The defendant seeks reconsideration of a prior award holding them responsible for Dr. Adelberg's $4,237.50 report. The defendant argues the judge ignored a prior order for an Agreed Medical Evaluation (AME) and that the applicant's attorney improperly proceeded with Dr. Adelberg's exam. The Board granted reconsideration, preliminarily finding it may be inequitable to place the full cost on the defendant, and intends to split the expense between the defendant and applicant's attorney. A dissenting opinion argues the defendant's own correspondence shows an ongoing dispute regarding the AME, supporting the original award of liability.

Workers' Compensation Appeals BoardReconsiderationMedical-Legal ReportAgreed Medical EvaluationQualified Medical EvaluatorJoint Findings and AwardLabor Code Section 4062(a)Stipulation and OrderEquitable PowersLien Claimant
References
1
Case No. ADJ18498378
Regular
Oct 27, 2025

MARIA VENEGAS vs. MARATHON PETROLEUM COMPANY, ACE AMERICAN INSURANCE

Lien claimant, Premier Psychological Services, sought reconsideration of a Findings and Order from July 30, 2025, which denied its lien for medical-legal and medical treatment expenses. The Workers' Compensation Appeals Board (WCAB) granted the petition for reconsideration, rescinded the original F&O, and returned the matter to the trial level for further proceedings. The Board found that the medical-legal expenses were incurred for a contested claim and that the medical report from Dr. Mark Michaels constituted substantial medical evidence for an injury arising out of and in the course of employment, despite some curable deficiencies regarding interpreter information. The WCAB ordered further consideration of the medical treatment expenses and a potential updated utilization review.

Premier Psychological ServicesAdjudication Number ADJ18498378Opinion and Order Granting Petition for ReconsiderationDecision After ReconsiderationLien ClaimantPrimary Treating Physician (PTP)Dr. Mark MichaelsInjury Arising Out of and In the Course of Employment (AOE/COE)PsycheMedical-Legal Report
References
21
Case No. MISSING
Regular Panel Decision

Wood v. Firestone Tire & Rubber Co.

Anthony N. Wood, severely injured while employed by the Town of Stillwater Highway Department, settled a third-party action against Firestone Tire and Rubber Company for $1.1 million. The workers' compensation carrier, Saratoga County Self-Insured Plan, had a lien of over $63,000 for compensation and medical payments. Wood moved to apportion legal fees and expenses against the carrier's lien, arguing that the carrier's equitable share should consider the present value of estimated future benefits it would no longer have to pay, citing *Matter of Kelly v State Ins. Fund*. The Saratoga County Self-Insured Plan opposed, disputing the calculation of future benefits and arguing for consideration of potential future death benefits. The court, guided by *Kelly*, found the respondent's arguments lacked merit and applied a formula that included the lien amount plus the discounted value of future payments saved by the carrier. The court determined an equitable apportionment of $114,112.67, concluding that the offset exceeded the carrier's lien due to the substantial benefits the carrier received from the extinguishment of future obligations.

ApportionmentLegal FeesThird-Party ActionLien OffsetFuture Benefits CalculationEquitable ApportionmentSettlement ProceedsEconomist Expert WitnessPermanent DisabilityCarrier Liability
References
10
Case No. ADJ8060110, ADJ8060106
Regular
Sep 28, 2018

VICTOR SANTOYO vs. WEST CENTRAL PRODUCE, ZENITH INSURANCE COMPANY

The Workers' Compensation Appeals Board denied reconsideration of a lien claim for medical-legal expenses. The claimant failed to prove a contested claim existed at the time the expenses were incurred, a prerequisite for employer liability under Labor Code sections 4620 and 4621. Copy service fees for medical records are considered medical-legal expenses, but the claimant bore the burden of proving their necessity and the existence of a contested claim. The Board adopted the WCJ's report, excluding discussion on the "existence of contested claim" from their specific reasoning.

Workers' Compensation Appeals BoardVictor SantoyoWest Central ProduceZenith Insurance CompanyPetition for ReconsiderationDenyLabor Code Section 4622Medical-Legal ExpensesLien ClaimantContested Claim
References
5
Case No. MISSING
Regular Panel Decision

Legal Aid Society v. Association of Legal Aid Attorneys

The Legal Aid Society sought a preliminary injunction against the Association of Legal Aid Attorneys and its officers to prevent the disciplining of striking union members who crossed picket lines. The plaintiff also claimed tortious interference and a civil rights conspiracy under 42 U.S.C. § 1985(3) on behalf of itself, non-striking attorneys, and indigent clients. The District Court denied the injunction, finding several impediments to success on the merits. These included the NLRB's primary jurisdiction, the Norris-LaGuardia Act's prohibitions, and the plaintiff's lack of standing for third-party claims. Furthermore, the court determined that the conspiracy allegations under Section 1985(3) were conclusory and lacked substantial merit.

Labor DisputePreliminary InjunctionUnion DisciplinePicket LinesNational Labor Relations Act (NLRA)Norris-LaGuardia ActStanding (Law)Conspiracy (Law)Civil Rights (42 U.S.C. § 1985(3))Tortious Interference
References
32
Case No. ADJ2337190 (LAO 0829672) ADJ3193895 (LAO 0829673) ADJ187762 (LAO 0829674)
Regular
Apr 21, 2009

OLIVIA HUERTA vs. GMP LABORATORIES, STATE COMPENSATION INSURANCE FUND

This case involves a lien claimant, Dr. Elena Konstat, seeking reconsideration of a Workers' Compensation Appeals Board decision that limited reimbursement for her medical-legal reports. The Board found that the original decision erred in disallowing two of Dr. Konstat's three medical-legal reports. The Board clarified that the Official Medical Fee Schedule for treatment rates does not apply to medical-legal expenses, and the testimony of the defendant's lien negotiator was not substantial evidence. Consequently, the Board granted reconsideration, rescinded the original finding, and substituted a new finding allowing reimbursement for all three of Dr. Konstat's medical-legal reports, with the exact amounts, penalties, and interest to be determined.

Medical-legal lienReconsiderationFindings and AwardIndustrial injuryNervous system injuryPsycheLicensed clinical psychologistMedical-legal expensesOfficial Medical Fee Schedule (OMFS)Compromise and Release (C&R)
References
1
Case No. MISSING
Regular Panel Decision

Goldberg v. Edson

The plaintiffs appealed two orders from the Supreme Court, Rockland County. The first order, dated January 5, 2006, granted summary judgment to defendants Page Edson and the County of Rockland, dismissing the complaint against them regarding claims of legal and medical malpractice. The second order, dated January 23, 2006, granted summary judgment to defendant Elizabeth O’Connor, dismissing the complaint against her for legal malpractice. The appellate court affirmed both orders, finding that Edson and the County were immune from liability under Social Services Law § 419 for reporting suspected child abuse and removing a child, and that O’Connor was not negligent in her legal services.

Legal MalpracticeMedical MalpracticeSummary JudgmentChild Abuse ReportingSocial Services LawImmunityMandated ReportersAppellate ReviewGood FaithNegligence
References
6
Case No. ADJ4382005 (MON 0329533)
Regular
Jun 09, 2010

AN TNEAL GOFFNEY vs. CITY OF LOS ANGELES, DEPARTMENT OF TRANSPORTATION, Permissibly Self-Insured

The Workers' Compensation Appeals Board granted the lien claimant's petition for reconsideration, striking the previous finding that there was no claim for medical-legal expenses. The Board found that the lien claimant's petition was timely filed and that there appeared to be valid medical-legal expenses that should be evaluated. The decision of the administrative law judge was otherwise affirmed. The matter was returned to the trial level for further proceedings concerning these expenses.

Workers' Compensation Appeals BoardLien ClaimantPetition for ReconsiderationFindings and OrderMedical-legal expenseLabor Code section 5402Labor Code section 5909Due processLabor Code section 4903(b)Labor Code section 4620
References
4
Case No. ADJ7796014
Regular
May 27, 2014

MAXIMINO COVARRUBIAS vs. WILLIAMS FURNACE COMPANY, ST. PAUL TRAVELERS INSURANCE COMPANY

The Workers' Compensation Appeals Board denied a petition for reconsideration from a medical provider and lien claimant. The claimant, Dr. Pedram Navab and Inland Empire Sleep Medicine, sought reimbursement for services as medical-legal expenses. However, the Board affirmed the WCJ's decision to disallow the liens because the petitioners failed to meet their burden of proof. Specifically, they did not provide adequate billing or evidence that the services qualified as medical-legal expenses, nor did they demonstrate the reports were properly requested.

Workers' Compensation Appeals BoardMaximino CovarrubiasWilliams Furnace CompanySt. Paul Travelers Insurance CompanyPetition for ReconsiderationLien Claimant NetworkMedical Legal ExpenseBurden of ProofFindings and OrderCompromise and Release
References
4
Case No. ADJ9116549
Regular
Mar 13, 2020

EMMA MEDINA vs. SUNRISE RESTAURANT, LLC, DENNY'S RESTAURANT, CANNON COCHRAN MANAGEMENT SERVICES, CHUBB INSURANCE

This Workers' Compensation Appeals Board case concerns the reimbursement for lien claimant Preferred Scan's copy services. The Board granted reconsideration to clarify what constitutes medical-legal expenses and the reasonable value of copy services. The Appeals Board rescinded the original award and returned the matter for further proceedings, finding that certain copy services for medical records were properly considered medical-legal expenses. However, the reasoning for doubling the copy service fee schedule was insufficient and requires further development at the trial level.

Workers' Compensation Appeals BoardReconsiderationLien ClaimantCopy ServicesMedical-Legal ServicesCopy Service Fee ScheduleLabor CodeSubpoena Duces TecumExplanation of ReviewCompromise and Release
References
4
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