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

Case No. ADJ13227834
Regular
Oct 10, 2025

Efren Sifuentes Nava vs. San Carlos Roofing Company, State Compensation Insurance Fund

Defendant SCIF filed a petition for removal challenging an order to serve medical records issued on December 2, 2024, by a workers' compensation administrative law judge (WCJ). The WCJ recommended dismissal because the defendant's objection to the order included a self-destruct clause, rendering the original order moot upon objection. The Appeals Board agreed that there was no active order to challenge and further noted the permissibility of a WCJ rescinding an offending order to promote judicial economy. Therefore, the Petition for Removal was dismissed as moot.

Petition for RemovalWCJ OrderSelf-Destruct ClauseMootRescissionJudicial EconomyAppeals BoardCost PetitionerMedical RecordsAdjudication Number
References
Case No. ADJ3714425 (FRE 0234250) ADJ896033 (FRE 0171714)
Regular
Aug 22, 2014

MICHAEL WRIGHT vs. STAR MEDIA, TRAVELERS INDEMNITY COMPANY OF CONNECTICUT

The Workers' Compensation Appeals Board granted reconsideration, rescinding a WCJ's order that enforced a reimbursement order against Travelers Indemnity Company. The Board found the reimbursement order void *ab initio* due to procedural due process infirmities. Specifically, the "self-destruct" clause in the order did not comport with due process protections outlined in precedent cases like *Mitchell v. Golden Eagle Ins.*, failing to guarantee a review of objections or automatically void the order upon valid objection. Therefore, Travelers' due process rights were violated, necessitating the rescission of the WCJ's findings.

Workers' Compensation Appeals BoardPetition for ReconsiderationOrder for ReimbursementCalifornia Insurance Guarantee Association (CIGA)Cumulative Trauma InjuryAgreed Medical Examiner (AME)ApportionmentDue ProcessSelf-Destruct ClauseVoid Ab Initio
References
Case No. ADJ3910048 (VNO 0417016)
Regular
Jul 30, 2010

NAHID JAVADI vs. SIMI VALLEY HOSPITAL, ADVENTIST HEALTH SYSTEMS WEST

This case involves an employer, Simi Valley Hospital/Adventist Health Systems West, seeking to prevent the joinder of AIG as a defendant in a workers' compensation claim. The employer argues it is permissibly self-insured and self-administered, and joining AIG, an excess carrier, would cause irreparable harm. The Appeals Board found that since there is no third-party administrator involved, the precedent relied upon for joinder is inapplicable. Consequently, the Board rescinded all orders joining AIG and returned the case to the trial level.

Workers' Compensation Appeals BoardPetition for RemovalJoinder of DefendantReinsurance CarrierExcess CarrierPermissibly Self-InsuredSelf-AdministeredIndustrial InjuryFindings and AwardPetition to Reopen
References
Case No. ADJ19199519; ADJ19199522
Regular
Feb 18, 2025

LAURA RODRIGUEZ vs. 99 CENTS ONLY STORES, SELF-INSURER'S SECURITY FUND

The Self-Insurers' Security Fund (SISF) petitioned for reconsideration or removal of a Workers' Compensation Judge's (WCJ) order denying its joinder in a case involving injured applicant Laura Rodriguez and the bankrupt 99 Cents Only Stores. The WCJ had ruled that SISF, having assumed the insolvent employer's liabilities, only needed to file a notice of change in administrator, not a joinder petition. The Appeals Board dismissed the petition for reconsideration as the order was not final, but granted the petition for removal. As its Decision After Removal, the Appeals Board rescinded the WCJ's December 2, 2024 order, finding due process violations due to the summary denial without a hearing, and returned the matter to the trial level for further proceedings.

Self-Insurers' Security Fundjoinderremovalreconsiderationinsolvent self-insurerliquidationadministrative law judgeorderdue processsubstantial evidence
References
Case No. ADJ6552646
Regular
Mar 26, 2014

CYNTHIA MOLINA vs. NORDSTROM, INC.

The Workers' Compensation Appeals Board (WCAB) rescinded a prior ruling that held the applicant responsible for medical bills incurred outside Nordstrom's Medical Provider Network (MPN). The WCAB determined that a "hold-harmless" clause in a stipulated award had no legal effect, as employers cannot assign their statutory duty to provide medical treatment. Lien claimants are subject to the WCAB's exclusive jurisdiction and can only recover from the employer under Labor Code section 4600 if the employer neglected to provide treatment. For self-procured treatment under section 4605, the employee is personally liable, and providers must pursue collection in civil court, not through WCAB liens.

Workers' Compensation Appeals BoardNordstrom Inc.Medical Provider NetworkStipulations with Request for AwardLabor Code Section 3751(b)Labor Code Section 4605Hold-Harmless ClauseLien ClaimsSelf-Procured TreatmentExclusive Jurisdiction
References
Case No. SRO 0121152
Regular
Dec 12, 2007

GINGER DUNLAP-FENTON vs. EEL RIVER SAWMILLS, SELF-INSURERS' SECURITY FUND

This case involved a defendant's petition for reconsideration of an award for an applicant's industrial neck injury. The appeals board granted reconsideration, amending the original award to reduce the permanent disability rating from 23% to 17% and adjusting the applicant's attorney fees. The board adopted the WCJ's report, which specified the revised permanent disability indemnity, the calculation of attorney fees on remaining temporary disability and self-procured medical expenses, and affirmed other aspects of the original award.

Workers Compensation Appeals BoardEel River SawmillsSelf-Insurers' Security Fundindustrial injuryblock stackerbankruptcytemporary total disabilitypermanent disabilityapportionmentself-procured medical treatment
References
Case No. ADJ7672393
Regular
Mar 07, 2013

MAURICE WILLIAMS vs. JACKSONVILLE JAGUARS, USF&G, ACE INSURANCE

This case concerns Maurice Williams, a former professional football player for the Jacksonville Jaguars, who sought workers' compensation benefits in California for a cumulative injury sustained between 2001 and 2009. While a portion of his employment exposed him to California, his contracts from 2007-2011 contained a mandatory forum selection clause requiring all injury claims to be resolved in Florida under Florida law. The Board affirmed the trial judge's decision to decline jurisdiction, finding the forum selection clause to be reasonable and binding for the latter portion of the cumulative injury period. Enforcement of the clause was not deemed unreasonable or unjust, and the applicant failed to demonstrate why California jurisdiction should be exercised despite the contractual agreement.

Workers' Compensation Appeals BoardJacksonville JaguarsUSF&GACE INSURANCEOpinion and Decision After Reconsiderationindustrial injuryorthopedic body partscumulative injurysubject matter jurisdictionforum selection clause
References
Case No. ADJ9438610
Regular
Sep 26, 2014

LUIS MENDIZABAL vs. C. E. LIMITED, INC., dba CENTRAL ENTERPRISES, ZENITH NORTH AMERICAN COMMERCIAL INSURANCE

The Workers' Compensation Appeals Board granted reconsideration, rescinding prior findings that the defendant failed to provide MPN information and that the applicant properly self-procured care. The Board found the defendant timely provided MPN notice in May 2014, not May 2013 as initially determined. Consequently, the defendant is not liable for self-procured treatment, and the case is returned to the trial level.

Medical Provider NetworkMPN transfer of careself-procured medical treatmentreconsiderationFindings of FactWCJadministrative law judgeindustrial injuryright kneenotice of transfer
References
Case No. ADJ7460656
En Banc
Jan 15, 2013

DENNIS MCKINLEY vs. ARIZONA CARDINALS, THE TRAVELERS INDEMNITY COMPANY

The Appeals Board affirmed the WCJ's decision, declining to exercise jurisdiction over a cumulative injury claim due to a reasonable mandatory forum selection clause in the employment contract specifying Arizona as the forum, coupled with the applicant's limited connection to California.

WORKERS' COMPENSATION APPEALS BOARDEN BANCCUMULATIVE INJURYPROFESSIONAL FOOTBALL PLAYERARIZONA CARDINALSTRAVELERS INDEMNITY COMPANYFORUM SELECTION CLAUSEMANDATORY FORUMLIMITED CONNECTIONEMPLOYMENT CONTRACT
References
Case No. LBO 0375714
Regular
Jul 09, 2008

VICENTE CARMEN vs. SKB CORPORATION

This case involves a lien claim by California Pharmacy Management for medication provided to an injured worker, Vicente Carmen. The Workers' Compensation Appeals Board denied reconsideration, upholding the finding that the pharmacy's lien was invalid because the medication was not prescribed by a physician within the defendant employer's Medical Provider Network (MPN). The Board reiterated that once an employer provides a MPN, an employee's self-procured treatment outside that network is not compensable, and the pharmacy's reliance on Labor Code section 4600.2 was misplaced as there was no evidence of a contract with the employer.

MPNLien claimMedical treatmentSelf-procuredPharmacy benefit networkLabor Code section 4600.2Treating physicianWorkers' Compensation Appeals BoardFindings and OrderReconsideration
References
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