WCPanelIQ
PanelLienRemanded

Delgado, Marcos

MARCOS DELGADO, Applicant vs. TADEMA CATTLE COMPANY; NATIONWIDE AGRIBUSINESS, Defendants

ADJ number
ADJ13810218
Decision date
Jan 19, 2026
District office
Riverside
WCJ
—
Claim administrator
Nationwide Agribusiness
Commissioners
KATHERINE A. ZALEWSKI, CHAIR, JOSEPH V. CAPURRO, COMMISSIONER, PAUL F. KELLY, COMMISSIONER
LC §5311LC §5700LC §15LC §5001LC §5002LC §4061LC §4061(h)(2)CCR §10960CCR §10346CCR §10700CCR §10788

Summary

Lien claimant Susan Garrett (Garrett Law Glendale) petitioned to disqualify the assigned WCJ, alleging the WCJ expressed unqualified opinions on the merits of the lien claim and engaged in improper ex-parte communication with the applicant. The Board did not reach those allegations, instead finding the underlying matter—division of an attorney's fee award arising from a Compromise and Release—was improperly set before the current WCJ. Under Labor Code section 5700, supplemental proceedings must return to the WCJ who originally heard the matter, here WCJ Wilson, who approved the C&R and made the initial attorney's fee determination. The Board granted the Petition for Disqualification on other grounds and returned the matter to the Presiding WCJ for reassignment to WCJ Wilson, or another WCJ if Wilson is unavailable.

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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