Ledezma, Alfredo, et al.

In this en banc decision, the WCAB imposed sanctions against attorney Susan Garrett and non-attorney Lance Garrett of Garrett Law Group for filing eight frivolous petitions for reconsideration across eight consolidated cases. In each case, after their last-minute continuance requests were denied, the Garretts filed petitions for reconsideration (often on the morning of trial) and failed to appear, which automatically halted trial proceedings and effectively obtained de facto continuances through improper means. The Board found the petitions were indisputably without merit and filed with willful intent to disrupt or delay proceedings, noting petitions for reconsideration are improper for orders setting matters for trial (interlocutory orders should be challenged by petition for removal). The Board rejected the Garretts' defenses—that alternative pleading is common practice, that good cause existed for continuances, and that the conduct was a mere 'inconvenience.' The Board imposed the maximum $2,500 sanction per case against each individual ($20,000 each, $40,000 total) plus reasonable expenses and attorney's fees, with the fee amount deferred to the trial level before PJ Robert Rassp.