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PanelRemanded

Alonso, Gabriel

GABRIEL ALONSO, Applicant vs. LAZY DOG RESTAURANT AND BAR; GENERAL CASUALTY COMPANY OF WISCONSIN, administered by QBE SPECIALTY INSURANCE, Defendants

ADJ number: ADJ16419247
Decision date: Jan 22, 2026
District office: Pomona
WCJ: —
Claim administrator: QBE Specialty Insurance (administering General Casualty Company of Wisconsin)
Commissioners: JOSÉ H. RAZO, COMMISSIONER, KATHERINE WILLIAMS DODD, COMMISSIONER, JOSEPH V. CAPURRO, COMMISSIONER

Injury / body parts: multiple body parts (cumulative trauma), fingers

LC §5814LC §5814.5LC §5800LC §5909LC §5900LC §5313LC §4903LC §4906LC §3700CCR §10600CCR §10775CCR §10776CCR §10778

Summary

Applicant Gabriel Alonso settled two claimed injuries by Compromise & Release for $95,000, with the C&R providing that interest was waived if payment was made within 30 days of the order approving the C&R. Defendant made multiple mailing attempts to applicant's attorney that were returned to sender, with successful delivery via FedEx only on August 28, 2025. The WCJ found the attorney fee payment untimely and awarded interest, a section 5814(a) penalty, and section 5814.5 attorney fees totaling $3,820.86. The Appeals Board granted reconsideration, holding the record was inadequate because the matter was submitted on stipulations alone, without testimony or exhibits, making it impossible to determine whether defendant's behavior was unreasonable. The Board rescinded the F&A and returned the matter to the trial level to develop a complete evidentiary record.

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.