WCPanelIQ
PanelMed-legalLienDenied

Williams, Michael

MICHAEL WILLIAMS, Applicant vs. UNIFIED GROCERS; OLD REPUBLIC INSURANCE; administered by CONSTITUTION STATE SERVICES, Defendants

ADJ number
ADJ17872943
Decision date
May 11, 2025
District office
Santa Ana
WCJ
Oliver Cathey
Claim administrator
Constitution State Services
Commissioners
—

Injury / body parts: back, lumbar spine, psyche

LC §5909LC §5900LC §3202.5CCR §10600

Summary

Spectrum Medical Group, a lien claimant, sought reconsideration of a WCJ's finding that applicant Michael Williams, a CDL driver, did not sustain an industrial injury to his back and psyche during a continuous trauma period of January 1, 2020 through May 1, 2023. The case in chief had settled by Compromise and Release, and the lien dispute proceeded on the issues of AOE/COE, the lien for med-legal and treatment, and reasonableness of charges. The WCJ found the testimony of defendant's witness Edward Chavez (the applicant's department manager) credible, establishing that applicant's job did not involve the heavy lifting, repetitive twisting, and prolonged walking that applicant had reported to the treating physician Dr. Amin Nia. Because Dr. Nia relied on an inaccurate job-duties history, the WCJ found his report was not substantial medical evidence and could not support a finding of industrial injury, leaving the lien claimant unable to meet its burden of proof. The WCAB adopted and incorporated the WCJ's Report, gave great weight to the credibility determination under Garza, and denied reconsideration.

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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