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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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Holding
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Analysis
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Applicant takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Defense takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Provider takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Similar decisions
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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