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.
From the decision · page 1Lien Claimant, California Imaging Solutions petitioned for reconsideration of the Findings and Order issued by the workers' compensation administrative law judge (WCJ) in this matter on March 23, 2022. In that decision, the WCJ found that a contested claim did not exist at the time lien claimant's copy services were incurred under Labor Code Section 4620 and that its medical- legal services were not reasonably, actually, and necessarily incurred pursuant to Labor Code Section 4621. The WCJ further ordered that the lien claimant take nothing on their lien.
The facts that decided it
What the panel treated as outcome-determinative, and which side it favoured.
The WCJ found no contested claim existed at the time lien claimant's copy services were incurred.
Favours Defendant prevailed
This finding led to denial of lien claimant's entitlement under Labor Code Section 4620.
From the decision · page 1Lien Claimant, California Imaging Solutions petitioned for reconsideration of the Findings and Order issued by the workers' compensation administrative law judge (WCJ) in this matter on March 23, 2022. In that decision, the WCJ found that a contested claim did not exist at the time lien claimant's copy services were incurred under Labor Code Section 4620 and that its medical- legal services were not reasonably, actually, and necessarily incurred pursuant to Labor Code Section 4621. The WCJ further ordered that the lien claimant take nothing on their lien.
The WCJ found lien claimant's medical-legal services were not reasonably, actually, and necessarily incurred.
Favours Defendant prevailed
This finding led to denial of lien claimant's entitlement under Labor Code Section 4621.
From the decision · page 1Lien Claimant, California Imaging Solutions petitioned for reconsideration of the Findings and Order issued by the workers' compensation administrative law judge (WCJ) in this matter on March 23, 2022. In that decision, the WCJ found that a contested claim did not exist at the time lien claimant's copy services were incurred under Labor Code Section 4620 and that its medical- legal services were not reasonably, actually, and necessarily incurred pursuant to Labor Code Section 4621. The WCJ further ordered that the lien claimant take nothing on their lien.
Favours Applicant prevailed
This settlement resolved the dispute and led to the WCAB's approval and rescission of the prior order.
The rules the panel named
Authorities as the decision cited them, with how this panel applied each one.
Labor Code Section 4620
Labor Code Section 4620
Lien claimant's copy services must be incurred during a contested claim to be compensable.
From the decision · page 1Lien Claimant, California Imaging Solutions petitioned for reconsideration of the Findings and Order issued by the workers' compensation administrative law judge (WCJ) in this matter on March 23, 2022. In that decision, the WCJ found that a contested claim did not exist at the time lien claimant's copy services were incurred under Labor Code Section 4620 and that its medical- legal services were not reasonably, actually, and necessarily incurred pursuant to Labor Code Section 4621. The WCJ further ordered that the lien claimant take nothing on their lien.
Labor Code Section 4621
Labor Code Section 4621
Medical-legal services must be reasonably, actually, and necessarily incurred to be compensable.
From the decision · page 1Lien Claimant, California Imaging Solutions petitioned for reconsideration of the Findings and Order issued by the workers' compensation administrative law judge (WCJ) in this matter on March 23, 2022. In that decision, the WCJ found that a contested claim did not exist at the time lien claimant's copy services were incurred under Labor Code Section 4620 and that its medical- legal services were not reasonably, actually, and necessarily incurred pursuant to Labor Code Section 4621. The WCJ further ordered that the lien claimant take nothing on their lien.
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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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