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PanelQMEMed-legalDenied

Milton, Sheila

SHEILA MILTON, Applicant vs. EAST BAY INNOVATIONS; NATIONAL CASUALTY COMPANY, administered by ILLINOIS MIDWEST INSURANCE AGENCY, LLC, Defendants

ADJ number: ADJ21458754
Decision date: Mar 2, 2026
District office: Oakland
WCJ: —
Claim administrator: Illinois Midwest Insurance Agency, LLC (administering National Casualty Company)
Commissioners: ANNE SCHMITZ, DEPUTY COMMISSIONER, KATHERINE WILLIAMS DODD, COMMISSIONER, JOSEPH V. CAPURRO, COMMISSIONER

Injury / body parts: cervical spine, lumbar spine, right knee, left wrist, head (claimed)

LC §5909LC §5900LC §5904LC §4060LC §4061LC §4062.2LC §3201CCR §30CCR §10955CCR §10517

Summary

Applicant Sheila Milton claimed an industrial injury on May 25, 2025 to her cervical spine, lumbar spine, right knee, and left wrist while employed by East Bay Innovations. Applicant's QME panel request listed an incorrect date of injury (May 20, 2025) but contained the correct claim number; defendant sought to invalidate the panel on this basis. The WCJ found the panel valid, and defendant petitioned for removal. The Board treated the petition as one for reconsideration (because the decision also resolved threshold AOE/COE issues) but applied the removal standard since only the interlocutory QME panel issue was challenged. The Board held that an incorrect date of injury does not invalidate a QME panel request where the claim number is correct, distinguishing claim-number errors (which are fatal) from date-of-injury errors (which are not). The petition was denied.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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Similar decisions

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Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.