What was disputed, and how it came out
Each issue the panel decided, with the reasoning it gave. An outcome is what this panel did on this record — not a rule, and not a prediction.
The tribunal found that Paperwork & More had notice of the hearing and failed to offer a reasonable excuse for non-appearance; sanctions were appropriate and imposed jointly and severally on Paperwork & More and Stanley B. Johnson, but not on Premier Psychological Services.
From the decision · page 7Whether Sanctions Should be Imposed Against Lien Claimant and/or their Representative [t]he regulations mandate that lien claimants appear at all lien conferences, either in person or by attorney or non-attorney representative.1 The failure to appear at a hearing is sanctionable conduct.2 Sanctions are appropriate for failures to appear where a reasonable excuse is not offered or the offending party has demonstrated a pattern of such conduct.3 (Emphasis added.)
The facts that decided it
What the panel treated as outcome-determinative, and which side it favoured.
Paperwork & More failed to offer a reasonable excuse for failure to attend the December 5, 2024 lien conference.
Favours Defendant prevailed
This failure justified the imposition of sanctions against Paperwork & More and Stanley B. Johnson.
From the decision · page 13FINDINGS OF FACT 1. Paperwork and More, on behalf of Premier Psychological Services, has failed to offer a reasonable excuse for their failure to attend the December 5, 2024 lien conference in accordance with CCR 10421(b)(1).
Paperwork & More and Stanley B. Johnson are jointly and severally responsible for the failure to attend the lien conference.
Favours Defendant prevailed
Sanctions were imposed jointly and severally on both for the failure to appear.
From the decision · page 132. Sanctions should be imposed against Paperwork and More and Stanley B. Johnson, jointly and severally, for the failure to attend the lien conference on December 5, 2024.
Premier Psychological Services did not fail to appear and sanctions were not imposed on it.
Favours Applicant prevailed
Sanctions were specifically not imposed on Premier Psychological Services for the non-appearance.
From the decision · page 133. Sanctions should not be imposed upon Premier Psychological Services for the failure to attend the lien conference on December 5, 2024.
The rules the panel named
Authorities as the decision cited them, with how this panel applied each one.
Lab. Code, § 4907(b); Lab. Code, § 5813
Non-attorney representatives are held to the same professional standards as attorneys; sanctions may be issued jointly and severally against a legal entity and the natural person responsible.
Sanctions here were issued jointly and severally against Paperwork & More and Stanley B. Johnson, the non-attorney representative.
From the decision · page 13With respect to sanctions, we note that section 5813, subdivision (a) authorizes a WCJ and/or the WCAB to "order a party, the party's attorney, or both, to pay any reasonable expenses, including attorney's fees and costs, incurred by another party as a result of bad-faith actions or tactics that are frivolous or solely intended to cause unnecessary delay." (Lab. Code, § 5813.) Under section 4907(b), non-attorney representatives appearing before the WCAB are held to the same professional standards of conduct as attorneys. (Lab. Code, § 4907(b).) We note that sanctions may be issued jointly and severally against a legal entity, such as a law firm, but orders issued pursuant to section 5813 for a representative's bad faith or frivolous tactics must identify the natural person against whom sanctions are being issued.
Cal. Code Regs., tit. 8, § 10875(a); CCR 10421(b)(1)
Lien claimants must appear at all lien conferences, either in person or by attorney or non-attorney representative; failure to appear is sanctionable conduct.
Sanctions are appropriate for failures to appear where a reasonable excuse is not offered or there is a pattern of conduct.
From the decision · page 7Whether Sanctions Should be Imposed Against Lien Claimant and/or their Representative [t]he regulations mandate that lien claimants appear at all lien conferences, either in person or by attorney or non-attorney representative.1 The failure to appear at a hearing is sanctionable conduct.2 Sanctions are appropriate for failures to appear where a reasonable excuse is not offered or the offending party has demonstrated a pattern of such conduct.3 (Emphasis added.)
Cal. Code Regs., tit. 8, § 10421(b)(1)
From the decision · page 11IV. With respect to the issue of sanctions, WCAB Rule 10421(b)(1) provides the following:
What proof carried it
The evidence the panel weighed, by kind.
Paperwork & More had notice of the hearing and failed to appear; the excuse of 'in-house clerical error' was not reasonable and lacked contrition.
From the decision · page 7The issue of sanctions seems to turn on whether there is a "reasonable excuse" offered. The record demonstrates that Paperwork had notice of the hearing that was missed, either actual notice from the Board or notice from Lien Claimant's own EAMS search. The Objection seems to blame an "in-house clerical error" for the non-appearance; however, there is no explanation as to what constitutes an "in-house clerical error." Paperwork's superficial statement as to "in-house clerical error" does not constitute a "reasonable excuse." Additionally, there is little to no contrition demonstrated by Paperwork in the record that warrants avoidance of sanctions. Lastly, the undersigned has reviewed and weighed Paperwork's numerous other exhibits offered and finds them of little to no relevant value on the issue of sanctions.10
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