Soto, Jeannette Renee

Applicant Jeannette Renee Soto, who has a 2008 stipulated award finding her permanently and totally disabled with lifetime medical care for a 1998 industrial injury, sought reconsideration of an October 8, 2025 F&A in which the WCJ found that a timely UR non-certification of previously authorized medications deprived him of jurisdiction to act. Applicant argued that under Patterson v. The Oaks Farm, redundant UR of previously authorized medications should be barred absent a change in circumstances, and that the WCJ's prior October 15, 2024 finding that the medications were reasonable and necessary should control. The Board found the present dispute purely legal but determined the record was not properly developed, particularly on whether collateral estoppel applied to the October 15, 2024 order, and noted that Patterson has recently been called into question by a Court of Appeal decision not yet final. The Board granted reconsideration and deferred a final decision pending further review and development of the record.