CompFox Logo
AboutWorkflowFeaturesPricingCase LawInsights

Updated Daily

Case Law Database

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

Case No. ADJ9417187
Regular
Jun 05, 2018

CARLOS CAMMON vs. COUNTY OF ORANGE permissibly selfinsured, administered by YORK RISK SERVICES GROUP, INC.

This case involves lien claimants Western Medical Center and Cedars Sinai seeking reconsideration of a decision regarding their unpaid medical bills. The administrative law judge had ruled the bills were subject to independent bill review and deemed satisfied due to a failure to request second bill review. The Appeals Board rescinded the original decision, finding that the threshold issue of whether the defendant was a beneficiary of a PPO contract needed to be determined first. Furthermore, the timeliness of Cedars Sinai's second bill review request remains unresolved, necessitating further proceedings to develop the record on this issue.

Workers' Compensation Appeals BoardLien ClaimantsIndependent Bill Review (IBR)Second Bill ReviewLabor Code Section 4603.2Labor Code Section 4603.3PPO ContractExplanation of Review (EOR)Guardian Ad LitemStipulations with Request for Award
References
0
Case No. ADJ9615494
Regular
Oct 08, 2019

CARLOS SOTO TORRES vs. THE CLIFF RESTAURANT, ZENITH INSURANCE COMPANY

The Workers' Compensation Appeals Board rescinded an Amended Findings of Fact and Order because essential documentation regarding the timeliness of medical-legal billings and reviews was missing. Specifically, the record lacked proof of service for the provider's invoice, the defendant's initial Explanation of Review (EOR), and the subsequent second bill review. This prevented determination of whether the defendant timely objected to the bill and whether the provider timely requested a second review, necessitating further proceedings at the trial level.

Workers' Compensation Appeals BoardReconsiderationAmended Findings of Fact and OrderQualified Medical EvaluatorQMEDr. Payam MoazzazZenith Insurance CompanyStatute of LimitationsLabor Code section 4903.5Independent Bill Review
References
0
Case No. ADJ8949526, ADJ8672351
Regular
Nov 05, 2018

ALFREDO ARGUETA vs. LA BREA DINING, ZENITH INSURANCE COMPANY

The Workers' Compensation Appeals Board denied reconsideration, upholding the administrative law judge's finding that the defendant was not liable for further payment on the lien claimant's invoices. The lien claimant argued the defendant's Explanation of Review (EOR) was deficient and thus they were not obligated to pursue a second bill review. The Board found this argument inconsistent with Labor Code section 4622, which requires timely objection to denied amounts, and adopted the WCJ's report. A dissenting opinion argued that a deficient EOR negates the requirement for a second bill review.

WCABLien claimantPetition for ReconsiderationExplanation of Review (EOR)Labor Code Section 4603.3Labor Code Section 4622Second Bill ReviewWCAB Rule 10451.1Perez v. Colorama Wholesale NurseryMedical-legal billing disputes
References
1
Case No. ADJ13768010
Regular
May 06, 2025

ROBERT NICHOLS vs. COMCAST, ACE AMERICAN INSURANCE COMPANY

Robert Nichols, the applicant, sustained injuries while employed by Comcast. A petition for reconsideration was filed regarding whether the medical treatment received by the applicant qualified as pre-admission or emergency services, and the defendant's alleged failure to conduct a second bill review. The Workers' Compensation Appeals Board denied the petition for reconsideration, concurring with the WCJ's report that the lien claimant did not provide sufficient evidence to demonstrate that the treatment fell under pre-admission or emergency status. The Board also noted that the issue concerning the defendant's non-response to the second bill review was not a contested matter at the trial.

PETITION FOR RECONSIDERATIONLABOR CODE SECTION 5909ELECTRONIC ADJUDICATION MANAGEMENT SYSTEM (EAMS)TRANSMISSION DATEREPORT AND RECOMMENDATIONLIEN CLAIMANTPRETREATMENT SERVICESEMERGENCY SERVICESMEDICARE PROSPECTIVE PAYMENT SYSTEMSECOND BILL REVIEW
References
7
Case No. ADJ9531226
Regular
Dec 04, 2018

JULICES MARTINEZ vs. SUN VALLEY GROUP, ZENITH INSURANCE COMPANY

The Workers' Compensation Appeals Board denied a lien claimant's petition for reconsideration, upholding the administrative law judge's decision. The lien claimant argued that the defendant's explanations of review (EORs) were deficient and did not trigger the lien claimant's obligation to request a second review. However, the Board found that the defendant's EORs substantially complied with statutory requirements and provided sufficient guidance to the lien claimant. Because the lien claimant failed to request a second review within the statutory timeframe, their objections to the billing were deemed waived.

Workers' Compensation Appeals BoardLien ClaimantExplanation of Review (EOR)Labor Code Section 4622Medical-legal ExpensesContested ClaimPetition for ReconsiderationAdministrative Director Rule 9794Second ReviewBill Review
References
7
Case No. ADJ7038469
Regular
Sep 17, 2014

AZIZA SAYED vs. GIORGIO ARMANI, FEDERAL INSURANCE COMPANY

The defendant's petition to appeal an Administrative Director's Independent Bill Review (IBR) determination was dismissed. The Board found the petition premature as it was not first heard by a trial level Workers' Compensation Judge (WCJ). Additionally, the petition failed to comply with numerous procedural requirements, including proper captioning, verification, service, and stating specific grounds for appeal. Consequently, both the petition for reconsideration and the petition appealing the IBR determination were dismissed.

Workers' Compensation Appeals BoardIndependent Bill ReviewPetition for ReconsiderationAdministrative DirectorLabor Code section 4603.6MAXIMUS Federal ServicesInc.Lien claimantOfficial Medical Fee ScheduleWCAB Rules of Practice and Procedure
References
0
Case No. ADJ11420360
Regular
Jul 01, 2025

Candelario Aleman vs. Logistics Dubois Corporation, Guard Insurance Company

The Workers' Compensation Appeals Board denied a Petition for Reconsideration filed by LRA Interpreters, Inc., a Cost Petitioner. The petitioner's claim for interpreting services was initially dismissed due to a lack of jurisdiction, as they failed to comply with Labor Code requirements for requesting a second bill review. The Board affirmed the WCJ's finding that although interpreting services could be considered medical-legal, the procedural steps for seeking further payment were not followed, thus preventing the WCJ from having jurisdiction to evaluate the reasonableness of the charges. The decision reinforces the necessity of adhering to established billing review procedures.

WCABPetition for ReconsiderationLabor Code60-day periodtransmissionEAMSnoticeReport and RecommendationCost PetitionerLRA Interpreters
References
2
Case No. ADJ8824674
Regular
Mar 15, 2018

MIGUEL MONTES vs. KOLE, INC. DBA QUALITY TUNE UP #8, ILLINOIS MIDWEST INSURANCE AGENCY, LLC, PROCENTURY INSURANCE COMPANY

This case concerns a Petition for Removal that the Workers' Compensation Appeals Board (WCAB) dismissed as untimely. The petitioner failed to file their removal petition within the prescribed 20-day period plus additional mailing time, submitting it one day late. Even if timely, the WCAB would have denied it on the merits, agreeing with the WCJ that the billing dispute was subject to Independent Bill Review (IBR) and not the WCAB's jurisdiction. The WCAB emphasized that if the sole dispute is the amount of payment and a second review failed, IBR is the proper avenue under Labor Code section 4603.6.

Petition for RemovalWorkers' Compensation Appeals BoardUntimely FilingService of OrderLegal MailingIndependent Bill ReviewLabor Code Section 4603.2Labor Code Section 4603.6Medical Provider NetworkJurisdiction
References
1
Case No. MISSING
Regular Panel Decision

Haddad v. City of Albany

The petitioner appealed a Supreme Court judgment that dismissed their application, which combined a CPLR article 78 proceeding and an action for declaratory judgment. The application challenged the respondent's denial of a request to rescind waste removal violation bills issued by the Department of General Services (DGS) of the City of Albany. The Supreme Court had found that the petitioner failed to exhaust administrative remedies and that claims regarding preemption of local waste ordinances by state penal law were without merit. During the pendency of the appeal, the Board of Zoning Appeals (BZA) administratively reviewed the violations, reversing some charges and upholding others. The appellate court affirmed the Supreme Court's judgment, concluding that a violation of the City of Albany's waste code was not a criminal violation under Penal Law § 55.10, and that the petitioner was indeed required to exhaust administrative remedies for their constitutional claims, as these claims implicated specific aspects of the administrative proceeding rather than the administrative scheme itself.

WasteManagementAdministrativeLawMunicipalCodePenalLawExhaustionOfRemediesDeclaratoryJudgmentAppellateReviewEnvironmentalViolationsPublicHealthPropertyMaintenance
References
10
Case No. 2022 NY Slip Op 01758 [203 AD3d 531]
Regular Panel Decision
Mar 15, 2022

Valentine v. 2147 Second Ave. LLC

Michael Valentine, a project safety coordinator for Homeland Safety Consultants, sued 2147 Second Avenue LLC and other defendants for injuries sustained at a demolition and construction site. The Supreme Court, Bronx County, granted summary judgment to defendants Gary Silver Architects, P.C. and Sunshine Quality Construction, Inc., dismissing the complaint against them, and denied Valentine's motion for partial summary judgment on his Labor Law § 240 (1) claim. The Appellate Division, First Department, affirmed this decision, finding no evidence of affirmative negligence by GSA and concluding that Sunshine was not on site as a general contractor until after the accident. The court also upheld the denial of Valentine's Labor Law claim, noting it was never properly pleaded in his complaints.

Demolition ProjectConstruction AccidentProject Safety CoordinatorSummary JudgmentLabor Law § 240 (1)Affirmative NegligenceGeneral Contractor LiabilityPleading AmendmentsAppellate ReviewPremises Liability
References
4
Showing 1-10 of 5,744 results

Ready to streamline your practice?

Apply these legal strategies instantly. CompFox helps you find decisions, analyze reports, and draft pleadings in minutes.

CompFox Logo

The AI standard for workers' compensation professionals. Faster research, deeper analysis, better outcomes.

Product

  • Platform
  • Workflow
  • Features
  • Pricing

Solutions

  • Defense Firms
  • Applicants' Attorneys
  • Insurance carriers
  • Medical Providers

Company

  • About
  • Insights
  • Case Law

Legal

  • Privacy
  • Terms
  • Trust
  • Cookies
  • Subscription

© 2026 CompFox Inc. All rights reserved.

Systems Operational