PanelLienRemanded
Bonilla, Maria
MARIA BONILLA, Applicant vs. EMBER CARE; TECHNOLOGY INSURANCE COMPANY; administered by AMTRUST; LIFE HOUSE HOLDINGS LLC; UNITED STATES FIRE INSURANCE COMPANY, Defendants
- ADJ number
- ADJ8371384
- Decision date
- Date unavailable
- District office
- Los Angeles
- WCJ
- —
- Claim administrator
- AmTrust (administering Technology Insurance Company); United States Fire Insurance Company
- Commissioners
- KATHERINE WILLIAMS DODD, COMMISSIONER, JOSÉ H. RAZO, COMMISSIONER, JOSEPH V. CAPURRO, COMMISSIONER
Injury / body parts: arms, fingers, back, shoulders, right hand, right wrist, left hand, left wrist, low back
LC §4600LC §4610LC §5307.27LC §5313LC §5502LC §5705LC §5900LC §5903LC §5909LC §5952CCR §9795.1CCR §9795.3CCR §10761
Summary
Lien claimants (Comprehensive Outpatient Surgery Center, California Urgent Care, Technical Surgery Support, Precision Interpreting, ABCDE Transportation, and Reliable Medical Supply) sought reconsideration of an August 18, 2025 Joint F&O in which the WCJ disallowed all their liens, finding they failed to meet their burden of proving the services were reasonably required to cure or relieve the effects of industrial injuries. The Board granted reconsideration, finding the WCJ erred in disregarding AME Dr. Danzig's reports (which addressed reasonableness/necessity of treatment) and in improperly interjecting himself into medical decisions despite extensive treatment evidence in the record. The Board also found the WCJ failed to apply the Guitron analysis regarding whether interpreters were provisionally certified, and that the transportation lien ledger lacked sufficient detail to evaluate. The Board rescinded the F&O and returned the matter to the trial level for further development of the record and a new decision.
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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