MIKE H. FORREST vs. APPLE CONTRACTING, STATE COMPENSATION INSURANCE FUND
This case involves a lien claimant seeking reimbursement for psychiatric treatment provided to an applicant whose employment duration precluded a valid industrial psychiatric injury claim. The applicant's orthopedic injury was accepted, and treatment for his psyche was initially authorized by the defendant. However, the Appeals Board denied the lien claimant's petition for reconsideration. The denial was based on the applicant not meeting the six-month employment requirement for psychiatric claims under Labor Code section 3208.3(d). Furthermore, the psychiatric treatment was not deemed a necessary pre-condition to treating the industrial orthopedic injury, and the lien claimant failed to establish the elements of estoppel against the defendant.