WCPanelIQ
PanelQMEMed-legalGranted

Salamat, Antonina

ANTONINA SALAMAT, Applicant vs. SBM SITE SERVICES, and SAFETY NATIONAL CASUALTY CORPORATION, administered by CANNON COCHRAN MANAGEMENT SERVICES, INC., Defendants

ADJ number
ADJ19203396
Decision date
Jan 20, 2025
District office
San Jose
WCJ
—
Claim administrator
Cannon Cochran Management Services, Inc. (CCMSI), administering for Safety National Casualty Corporation
Commissioners
CRAIG SNELLINGS, COMMISSIONER, JOSEPH V. CAPURRO, COMMISSIONER, JOSÉ H. RAZO, COMMISSIONER

Injury / body parts: left wrist, left knee, face, neck, upper extremities, back, lower extremities

LC §4060LC §4061LC §4062LC §4062.2LC §4062.3LC §4064LC §5709LC §5900LC §5902LC §5903LC §5909CCR §30CCR §10517CCR §10600CCR §10617CCR §10955CCR §10964

Summary

Applicant Antonina Salamat had two claims: a specific injury on August 29, 2023 (ADJ19457849) accepted for left wrist and knee, and a cumulative injury from January 1, 2020 through February 15, 2024 (ADJ19203396). After serving a section 4062.2 request referencing the cumulative claim, applicant's attorney obtained chiropractic panel 7694889 but mistakenly used the specific injury claim number on the panel request. The WCJ found applicant's panel invalid and defendant's later orthopedic panel 7705125 valid. The Appeals Board granted reconsideration, holding that under Navarro the same QME must evaluate both claims since both were filed before any evaluation, and that the wrong claim number was a technical, non-jurisdictional defect that did not invalidate the panel under the substance-over-form doctrine. The Board rescinded the F&O and substituted a new one finding applicant's panel 7694889 valid and defendant's panel 7705125 invalid.

Issues

Member is $25/month or $250/year and includes full case search.

Holding

Member is $25/month or $250/year and includes full case search.

Analysis

Member is $25/month or $250/year and includes full case search.

Applicant takeaway

Member is $25/month or $250/year and includes full case search.

Defense takeaway

Member is $25/month or $250/year and includes full case search.

Provider takeaway

Member is $25/month or $250/year and includes full case search.

Similar decisions

Member is $25/month or $250/year. Subscribe to view similar decisions.

Member is $25/month or $250/year. Subscribe to view similar decisions.

Member is $25/month or $250/year. Subscribe to view similar decisions.

Member is $25/month or $250/year. Subscribe to view similar decisions.

Member is $25/month or $250/year. Subscribe to view similar decisions.

Member is $25/month or $250/year. Subscribe to view similar decisions.

Member is $25/month or $250/year. Subscribe to view similar decisions.

Member is $25/month or $250/year. Subscribe to view similar decisions.