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. ADJ2984143 (LBO 0340645) MF ADJ3946341 (LBO 0340644) ADJ896223 (LBO 0340643)
Regular
Jun 26, 2012

FERNANDO GUZMAN vs. ACU-AIR CARGO, LLC, PARSONS TRANSPORTATION, LLC, UNINSURED EMPLOYERS BENEFITS TRUST FUND

The Workers' Compensation Appeals Board granted reconsideration, reversing the WCJ's decision that barred the applicant's claims due to the employer's bankruptcy. The Board clarified that a bankruptcy discharge injunction does not prevent a WCAB proceeding if the goal is to collect from a collateral source like the Uninsured Employers Benefits Trust Fund (UEF), not the discharged bankrupt employer personally. Relying on *In Re Munoz*, the Board held that a WCAB proceeding can continue to establish an award against the bankrupt employer, which is a necessary precursor for the UEF to pay. Therefore, the applicant may proceed with their claims before the WCAB, provided they stipulate they are not seeking personal recovery from the bankrupt employer.

UEFbankruptcy discharge injunctioncollateral sourcesubstantial shareholderLabor Code section 3717.1uninsured employerproof of claimautomatic staynondischargeable debtMunoz
References
Case No. ADJ7222908
Regular
Jan 15, 2014

FIDELINO DEL CID vs. VOLT INFORMATION SCIENCES, GALLAGHER BASSETT

Lien claimants sought reconsideration of a WCJ order dismissing their liens for failing to pay the Labor Code section 4903.06 activation fee. A federal court injunction had previously stayed enforcement of this fee provision. Consequently, the Appeals Board granted reconsideration, rescinded the dismissal orders, and returned the case for further proceedings. The lien claimants' liens are reinstated pending further action.

Lien activation feeLabor Code section 4903.06Angelotti Chiropractic v. Bakerpreliminary injunctionWorkers' Compensation Appeals BoardPetition for ReconsiderationWCJrescind orderslien claimantsfederal district court
References
Case No. ADJ7839177 ADJ7830355
Regular
Dec 03, 2013

CARLOS ORANTES vs. STANTEX, FIRSTCOMP INSURANCE

This case involves a lien claimant whose lien was dismissed for failing to pay the required activation fee under Labor Code section 4903.06. However, a federal court injunction subsequently barred the enforcement of this fee provision. Consequently, the Workers' Compensation Appeals Board (WCAB) granted reconsideration and rescinded the dismissal order. The matter is now returned to the administrative law judge for further proceedings.

Lien activation feeLabor Code section 4903.06Petition for ReconsiderationPreliminary injunctionAngelotti Chiropractic v. BakerWCJWorkers' Compensation Appeals BoardRescinded orderReturned to trial levelLien claimant
References
Case No. ADJ2452007 (STK 0169879)
Regular
Oct 11, 2018

EDUARDO ALBERDIN vs. STATE COMPENSATION INSURANCE FUND, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION

The Workers' Compensation Appeals Board (WCAB) rescinded a prior order dismissing lien claims for failure to pay activation fees. The WCAB found that the lien claimant's obligation to pay was impacted by the timing of U.S. District Court injunctions and subsequent vacating orders related to the fees. The matter is returned to the trial level to address lien identification and fee payment under the WCAB's clarified guidance.

Lien activation feesLabor Code section 4903.06Figueroa v. B.C Doering Co.Med-1 Medical CenterState Compensation Insurance FundCalifornia Insurance Guarantee AssociationWorkers' Compensation Appeals Boardconsolidationreconsiderationdue process
References
Case No. ADJ10037291
Regular
Apr 01, 2025

Adan Alvarez vs. Victor Manuel Martinez, Justine Marie Martinez

The Uninsured Employers Benefits Trust Fund (UEBTF) petitioned for reconsideration of a decision that allowed applicant Adan Alvarez to pursue a workers' compensation claim against Victor Manuel Martinez and Justine Marie Martinez despite his failure to file a proof of claim in the employers' bankruptcy proceedings. UEBTF contended that Alvarez was required to file a proof of claim in a Chapter 7 asset bankruptcy. The Appeals Board denied UEBTF's petition, affirming its prior decision. The Board distinguished this case from previous rulings, concluding that an employee's failure to file a proof of claim in bankruptcy is not fatal to their workers' compensation claim if no award exists at the time of the bankruptcy discharge.

UEBTFbankruptcyproof of claimChapter 7 assetChapter 7 no assetdischarge injunctionLabor Code section 3716Ortiz v. Workers' Comp. Appeals Bd.Slali v. RuizWCJ
References
Case No. ADJ8148545, ADJ8147711
Regular
Feb 05, 2014

LAZARO GUERRERO vs. UNITED PLUMBING SERVICE INC., BERKLEY SPECIALTY

The Workers' Compensation Appeals Board (WCAB) granted reconsideration of an order dismissing a lien claimant's lien for failure to pay the lien activation fee. This dismissal was rescinded because a federal court injunction prohibited the enforcement of the lien activation fee provisions of Labor Code section 4903.06. The case is returned to the WCJ for further proceedings, including consideration of the defendant's request for attorney's fees.

Petition for ReconsiderationLien Activation FeeLabor Code section 4903.06Preliminary InjunctionAngelotti Chiropractic v. BakerWCJ Order RescindedLien ClaimantWorkers' Compensation Appeals BoardFurther ProceedingsAttorney's Fees
References
Case No. ADJ1085807 (BAK 0154474) ADJ6601730
Regular
Sep 15, 2015

MARIA CORTEZ vs. KIRSCHENMAN ENTERPRISES, WAUSAU UNDERWRITERS INSURANCE COMPANY

The Workers' Compensation Appeals Board denied Dr. Moelleken's petition for reconsideration, affirming the disallowance of his lien. However, they granted Associated Reproduction Services' (ARS) petition, deferring their lien claim due to an ongoing federal injunction affecting lien dismissals for unpaid activation fees. The Ninth Circuit's decision vacating the injunction was not yet final, thus the injunction remained in effect. ARS's lien will be decided on its merits pending further developments.

Workers' Compensation Appeals BoardLien ClaimantsPetition for ReconsiderationFindings and OrdersAdministrative Law JudgeActivation FeeInjunctionMandateJudicial NoticeFederal Court
References
Case No. ADJ8189296
Regular
Dec 31, 2013

EXTRAIN QUINTANA vs. RANCHO GRANDE SUPERMARKET, NORTH RIVER INSURANCE CO. by CRUM & FORSTER

This case involves a petition for removal challenging an order for sanctions against a lien claimant for failing to pay a lien activation fee. The Appeals Board dismissed the petition for removal, finding reconsideration to be the proper avenue. However, construing the petition as a request for reconsideration, the Board granted it. The Board rescinded the sanctions order due to uncertainty regarding a federal injunction impacting the lien activation fee provisions and remanded the matter for further proceedings.

Workers' Compensation Appeals BoardPetition for RemovalPetition for ReconsiderationOrder to Pay SanctionsLien Activation FeeLabor Code section 4903.06Labor Code section 5813Preliminary InjunctionAngelotti Chiropractic v. BakerFederal Court Injunction
References
Case No. ADJ8105931
Regular
Dec 30, 2013

MARLA JACKSON vs. THE ARC OF SAN DIEGO, ALLIANT SPECIALTY INSURANCE SERVICES

This case concerns a lien claimant's petition for reconsideration of an order dismissing its lien due to failure to pay the required activation fee under Labor Code section 4903.06. The Workers' Compensation Appeals Board granted reconsideration, rescinding the dismissal. This action was based on a federal court's preliminary injunction that enjoined enforcement of the lien activation fee provisions effective November 19, 2013. The matter is returned to the WCJ for further proceedings.

Lien activation feeLabor Code section 4903.06Petition for ReconsiderationPreliminary injunctionAngelotti Chiropractic v. BakerWorkers' Compensation Appeals BoardWCJRescinded orderReturn to trial levelFederal district court injunction
References
Case No. ADJ7568371
Regular
Jan 22, 2014

LUIS ORTIZ vs. ICR STAFFING, INC., NATIONAL UNION FIRE INSURANCE COMPANY

This case involves a lien claimant whose lien was dismissed for failing to pay a required activation fee. However, a federal injunction had suspended enforcement of this fee provision at the time. The Appeals Board granted reconsideration, rescinded the dismissal order, and returned the case for further proceedings. This decision recognizes the impact of the injunction on the lien activation fee requirement.

Lien activation feeLabor Code section 4903.06Petition for ReconsiderationPreliminary injunctionAngelotti Chiropractic v. BakerWCJWorkers' Compensation Appeals BoardRescindedReturned to trial levelLien claimant
References
Showing 1-10 of 104 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