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

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. ADJ10428582
Regular
Jul 19, 2019

MICHAEL GELI vs. CENTER FOR BEHAVIORAL SCIENCES, THE HARTFORD

This case involves a lien claimant, Monrovia Hospital, seeking reconsideration after a Workers' Compensation Appeals Board decision denying their claim for additional payment. The claimant argued a lack of due process due to an unavailable expert witness and that their services were exempt from the Official Medical Fee Schedule (OMFS). The Board denied reconsideration, finding the claimant failed to subpoena their expert and did not provide adequate evidence to demonstrate their charges were reasonable and customary under the "reasonable cost basis" standard for non-OMFS services. Ultimately, the WCJ's finding that the defendant reasonably paid the amount awarded was upheld.

Lien claimantPetition for reconsiderationDue processExpert witnessReschedulingSubpoenaCross-examinationOfficial Medical Fee Schedule (OMFS)Reasonable cost basisLong term care hospital
References
5
Case No. MISSING
Regular Panel Decision

Porter v. Texaco, Inc.

Plaintiff Mona C. Porter filed an action against her employer, Texaco, Inc., alleging sex discrimination and retaliation under Title VII and the New York Human Rights Law, as well as intentional infliction of emotional distress. The core issue was whether Porter's sex discrimination claims were jurisdictionally sound, given that her EEOC charge only cited age discrimination and retaliation for participating in a class action, without alleging sex discrimination. The court determined that Porter's sex discrimination claims were not included in or reasonably related to her EEOC charge under any of the three established criteria (retaliation for filing EEOC charge, further incidents of discrimination in the same manner, or within the scope of a reasonable EEOC investigation). Furthermore, the retaliation claims in her Title VII complaint were also deemed not reasonably related to her EEOC charge due to differing conduct and forms of alleged retaliation. Consequently, the court lacked jurisdiction over the Title VII sex discrimination claim, and the defendant's motion for summary judgment was granted, leading to the dismissal of all federal claims. The supplemental state law claims were subsequently dismissed without prejudice.

Sex DiscriminationRetaliationTitle VIIEEOC ExhaustionSummary JudgmentFederal JurisdictionHuman Rights LawEmployment LawDiscrimination Claim
References
19
Case No. MISSING
Regular Panel Decision

Stair v. Calhoun

Plaintiffs' counsel, Ballon Stoll Bader & Nadler, P.C., moved to withdraw from representing plaintiffs and sought a charging and retaining lien due to plaintiff Theodore Stair's substantial unpaid legal fees. Stair opposed the withdrawal, citing a pending settlement. The court granted counsel's motion to withdraw, finding Stair's prolonged failure to pay constituted deliberate disregard of his financial obligations. The court also granted a charging lien for $37,546.87, representing adjusted reasonable hours and expenses, but denied the motion for a retaining lien to prevent prejudice to the ongoing litigation and due to Stair's alleged indigence.

Withdrawal of CounselCharging LienRetaining LienUnpaid Legal FeesAttorney-Client RelationshipDeliberate DisregardQuantum MeruitShareholder DilutionMotion PracticeFee Dispute
References
86
Case No. ADJ6704917
Regular
Apr 15, 2018

Victor Diaz vs. Cor O Van, Travelers Diamond Bar

This case involves a lien claimant, Monrovia Memorial Hospital, appealing a WCJ's decision that the defendant overpaid the lien claim and that penalties and interest were moot. The lien claimant argues its charges are customary and reasonable, not subject to the Official Medical Fee Schedule, and should be reimbursed on a "reasonable cost" basis. The Appeals Board granted reconsideration to further review the lien claimant's arguments and the WCJ's findings on payment sufficiency and fee schedule applicability.

Lien claimantPetition for ReconsiderationKunzTapiaOfficial Medical Fee ScheduleLong-term acute care hospitalReasonable cost basis42 Code of Federal RegulationsGouldMedically necessary
References
3
Case No. ADJ6845555, ADJ7392921, ADJ8509830
Regular
May 09, 2017

GLORIA ALOMIA vs. AAREN SCIENTIFIC, INC.; CYPRESS INSURANCE COMPANY

The Appeals Board affirmed the WCJ's decision regarding lien claimant Monrovia Memorial Hospital's payment, awarding them $\$52,000.00$. Monrovia sought additional payment and interest, arguing their services were not subject to the Official Medical Fee Schedule (OMFS) and should be paid on a reasonable cost basis. The Board found that while Monrovia is exempt from OMFS, lien claimants bear the burden of proving their charges are reasonable, not just their usual and customary fees. The claim for interest was also denied as Monrovia did not meet the criteria for payment under Labor Code section 4603.2.

Workers' Compensation Appeals BoardReconsiderationIndustrial InjuryCervical SpineLumbar SpineBilateral ShouldersBilateral WristsLien ClaimantMonrovia Memorial HospitalOfficial Medical Fee Schedule (OMFS)
References
2
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. ADJ577900 (STK 0187827)
Regular
Jul 18, 2011

DARIO MEDRANO vs. FEIST CABINETS, VIRGINIA SURETY

The Workers' Compensation Appeals Board granted reconsideration of a prior decision regarding Dr. Brown's medical lien. The Board found that the reasonableness and necessity of Dr. Brown's treatment charges for applicant's 2003 industrial neck and back injury require further review. While defendants failed to properly object to bills, Dr. Brown still bears the burden of proving reasonableness. The case is remanded for the WCJ to determine which specific charges were reasonable and necessary, subject to OMFS, penalties, and interest.

Workers' Compensation Appeals BoardReconsiderationMedical Treatment LienReasonableness and NecessityOfficial Medical Fee ScheduleBurden of ProofIndustrial InjuryCompromise and ReleaseBill ReviewAdministrative Director Rules
References
2
Case No. ADJ2831572 (OXN 0131269)
Regular
Dec 09, 2008

GRACIELA BELTRAN vs. TECHSTAFF WEST, INC., STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board denied a lien claimant's petition for reconsideration, upholding the original finding that the reasonable value of their services was $4,792.00, not the $12,435.54 claimed. The Board affirmed the Administrative Law Judge's decision, finding the lien claimant failed to meet its burden of proving the reasonableness of its charges under established precedent. The judge properly considered various evidence, including comparative data and the reasonableness of the charges in context, to arrive at the determined amount.

Workers' Compensation Appeals BoardLien ClaimantPetition for ReconsiderationFindings and OrderReasonable ValueIndustrial InjuryCompromise and ReleaseDiagnostically Related GroupMedicareFee Schedule
References
2
Case No. ADJ10160197 ADJ8200777
Regular
Sep 03, 2019

JOSE CARDENAS vs. COSTA VIEW FARMS, ZENITH INSURANCE COMPANY

The Workers' Compensation Appeals Board denied Monrovia Hospital's petition for reconsideration, upholding the original decision that the hospital was entitled to nothing further on its lien. The Board found that the hospital failed to meet its burden of proving its charges were based on a "reasonable cost basis" as required for long-term care facilities exempt from the Official Medical Fee Schedule. Expert testimony presented by both parties, particularly regarding cost-to-charge ratios derived from OSHPD data, supported the finding that the hospital's proposed methodologies did not adequately demonstrate reasonable costs. The Board affirmed that the hospital, not the defendant, bears the affirmative burden of proving the reasonableness of its lien.

Workers' Compensation Appeals BoardLien claimantPetition for ReconsiderationFindings and OrderMonrovia HospitalCosta View FarmsZenith Insurance CompanyWCJLabor Code section 5906reasonable cost basis
References
2
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