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 WCAB found that the lien claimant met the burden of proof to establish that the medical-legal report by Dr. Haghighinia was reasonable and necessary, issued after defendant denied the claim, and thus the defendant is liable for payment of medical-legal expenses.
The facts that decided it
What the panel treated as outcome-determinative, and which side it favoured.
Defendant denied liability for the applicant's claim on August 8, 2025, establishing a contested claim at the time of the medical-legal evaluation.
Favours Applicant prevailed
This denial triggered the contested claim status necessary for medical-legal expense liability under Labor Code section 4620.
From the decision · page 12Here, in Case Number ADJ21274145 on July 24, 2025, applicant’s attorney filed an Application claiming a cumulative injury from July 15, 2024 to July 15, 2025. On August 8, 2025, defendant issued a letter to applicant denying her claim for the date of injury of July 15, 2025. (Exhibit P, 8/8/2025.) On September 15, 2025, PTP Dr. Haghighinia examined applicant and issued a medical-legal report for the purpose of proving applicant’s cumulative injury claim. (Exhibit 2, 9/15/2025.) The parties entered into a C&R for Case Numbers ADJ21274168 and ADJ21274145. A WCJ signed a Joint Order Approving the C&R dated December 4, 2025, resolving both cases. In the instant case, medical-legal reporting from a treating physician is relevant and admissible and provides a basis for a decision. Lien claimant demonstrated that PTP Dr. Haghighinia’s medical-legal report was reasonable and necessary, since the report issued after defendant denied applicant’s claim.
Dr. Haghighinia's medical-legal report was issued on September 15, 2025, after the denial of the claim, and was requested by the applicant's attorney to address disputed medical issues.
Favours Applicant prevailed
The timing and purpose of the report established it as a reasonable and necessary medical-legal evaluation for the contested claim.
From the decision · page 12Here, in Case Number ADJ21274145 on July 24, 2025, applicant’s attorney filed an Application claiming a cumulative injury from July 15, 2024 to July 15, 2025. On August 8, 2025, defendant issued a letter to applicant denying her claim for the date of injury of July 15, 2025. (Exhibit P, 8/8/2025.) On September 15, 2025, PTP Dr. Haghighinia examined applicant and issued a medical-legal report for the purpose of proving applicant’s cumulative injury claim. (Exhibit 2, 9/15/2025.) The parties entered into a C&R for Case Numbers ADJ21274168 and ADJ21274145. A WCJ signed a Joint Order Approving the C&R dated December 4, 2025, resolving both cases. In the instant case, medical-legal reporting from a treating physician is relevant and admissible and provides a basis for a decision. Lien claimant demonstrated that PTP Dr. Haghighinia’s medical-legal report was reasonable and necessary, since the report issued after defendant denied applicant’s claim.
What the panel did with the medical opinions
The role the physician served, and the weight the opinion carried. Physicians are named here as the decision names them; we do not score them.
Opined that the applicant's progressive pain and discomfort in neck, lumbar spine, bilateral shoulders, and right ankle was due to cumulative effect of repetitive work activities, supporting causation for the claimed injury period July 15, 2024 to July 15, 2025.
The report was used to prove or disprove causation for the contested claim and was found reasonable and necessary by the WCAB.
From the decision · page 4With respect to causation, Dr. Haghighinia opined as follows:
The rules the panel named
Authorities as the decision cited them, with how this panel applied each one.
California Labor Code
Labor Code sections 4620, 4621, 4622 regarding medical-legal expenses and employer liability for reasonable and necessary medical-legal evaluations.
These statutes were applied to determine the lien claimant's entitlement to payment for the medical-legal report.
From the decision · page 8II. Section 4060(b) allows a medical-legal evaluation by the treating physician. Section 4620(a) defines medical-legal expense as “any costs and expenses…for the purpose of proving or disproving a contested claim.” Section 4064(a) states in part that “[T]he employer shall be liable for the cost of each reasonable and necessary comprehensive medical-legal evaluation obtained by the employee pursuant to Sections 4060, 4061, and 4062.” The regulations provide that the “primary treating physician shall render opinions on all medical issues necessary to determine the employee’s eligibility for compensation....” (Cal. Code Regs., tit. 8, §9785(d).) AD Rule 9793(h) states: (h) “Medical-legal expense” means any costs or expenses incurred by or on behalf of any party or parties, the administrative director, or the appeals board for X-rays, laboratory fees, other diagnostic tests, medical reports, medical records, medical testimony, and as needed, interpreter's fees, for the purpose of proving or disproving a contested claim. The cost of medical evaluations, diagnostic tests, and interpreters is not a medical-legal expense unless it is incidental to the production of a comprehensive medical-legal evaluation report, follow-up medical-legal evaluation report, or a supplemental medical-legal evaluation report and all of the following conditions exist:
California Code of Regulations
California Code of Regulations sections 9785 and 9793 regarding primary treating physician's medical-legal reporting duties and contested claims.
These regulations were cited to support the nature of the medical-legal report and contested claim status.
From the decision · page 8II. Section 4060(b) allows a medical-legal evaluation by the treating physician. Section 4620(a) defines medical-legal expense as “any costs and expenses…for the purpose of proving or disproving a contested claim.” Section 4064(a) states in part that “[T]he employer shall be liable for the cost of each reasonable and necessary comprehensive medical-legal evaluation obtained by the employee pursuant to Sections 4060, 4061, and 4062.” The regulations provide that the “primary treating physician shall render opinions on all medical issues necessary to determine the employee’s eligibility for compensation....” (Cal. Code Regs., tit. 8, §9785(d).) AD Rule 9793(h) states: (h) “Medical-legal expense” means any costs or expenses incurred by or on behalf of any party or parties, the administrative director, or the appeals board for X-rays, laboratory fees, other diagnostic tests, medical reports, medical records, medical testimony, and as needed, interpreter's fees, for the purpose of proving or disproving a contested claim. The cost of medical evaluations, diagnostic tests, and interpreters is not a medical-legal expense unless it is incidental to the production of a comprehensive medical-legal evaluation report, follow-up medical-legal evaluation report, or a supplemental medical-legal evaluation report and all of the following conditions exist:
WCAB Rule 10786
WCAB Rule 10786 regarding procedures for medical-legal expense objections and petitions.
Applied to procedural aspects of medical-legal expense disputes.
Warren Brower v. David Jones Construction (2014) 79 Cal.Comp.Cases 550 (Appeals Board en banc)
Warren Brower v. David Jones Construction (2014) 79 Cal.Comp.Cases 550 (Appeals Board en banc) establishing that a medical-legal report from a PTP is a medical-legal expense for which the defendant is liable.
Cited to support the entitlement to payment for a medical-legal report from a primary treating physician.
From the decision · page 9Read together, these sections provide that a medical-legal evaluation performed by an employee’s treating physician is a medical-legal evaluation obtained pursuant to section 4060 and that an employer is liable for the cost of reasonable and necessary medical-legal reports that are performed by the treating physician. The Appeals Board has previously held that there was no legal authority to support the proposition that an injured worker is not entitled to request a medical legal report from their PTP, and in turn, the report from that PTP is a medical-legal expense for which the defendant is liable. (Warren Brower v. David Jones Construction (2014) 79 Cal.Comp.Cases 550 (Appeals Board en banc).) Moreover, a medical-legal expense is ordinarily allowable if it is capable of proving or disproving a contested claim, if the expense was reasonably necessary at the time incurred, and if the cost incurred was reasonable. (Lab. Code, §§ 4620 et seq., 5307.6.) The Labor Code sections discussed above do not include the limitations set forth in AD Rule 9793(h).
What proof carried it
The evidence the panel weighed, by kind.
The medical-legal report by Dr. Haghighinia was issued after defendant denied the claim, establishing a contested claim existed at the time of service.
From the decision · page 12Here, in Case Number ADJ21274145 on July 24, 2025, applicant’s attorney filed an Application claiming a cumulative injury from July 15, 2024 to July 15, 2025. On August 8, 2025, defendant issued a letter to applicant denying her claim for the date of injury of July 15, 2025. (Exhibit P, 8/8/2025.) On September 15, 2025, PTP Dr. Haghighinia examined applicant and issued a medical-legal report for the purpose of proving applicant’s cumulative injury claim. (Exhibit 2, 9/15/2025.) The parties entered into a C&R for Case Numbers ADJ21274168 and ADJ21274145. A WCJ signed a Joint Order Approving the C&R dated December 4, 2025, resolving both cases. In the instant case, medical-legal reporting from a treating physician is relevant and admissible and provides a basis for a decision. Lien claimant demonstrated that PTP Dr. Haghighinia’s medical-legal report was reasonable and necessary, since the report issued after defendant denied applicant’s claim.
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About this page
- A published decision of the California Workers' Compensation Appeals Board, taken apart by what it turned on. The Board publishes the decision itself; this page adds the extraction and quotes the passage behind every claim.
- The injured worker is not named here, and the case caption is not printed. Physicians appear as the decision names them, because a medical opinion is an act in a public proceeding.
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