JUAN MEDINA vs. SANTA ANA PLATING, STATE COMPENSATION INSURANCE FUND SANTA ANA
This case involves a lien claimant, Main Street Specialty Surgery Center, seeking reimbursement for medical services provided to applicant Juan Medina for an industrial injury on December 13, 2002. The lien claimant filed its application for adjudication on May 29, 2008, over five years after the date of injury and the provision of medical services. The Workers' Compensation Appeals Board reversed the finding of the administrative law judge, holding that the lien claimant's claim is barred by Labor Code section 5405. The Board clarified that lien claimants initiating proceedings must adhere to the same statutes of limitations as the injured worker, and without a timely filed application, recovery is precluded.