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PanelLienGranted

Silvera, Jonathan

JONATHAN SILVERA, Applicant vs. J HOWARD IV, LLC dba PRIME PIZZA; HARTFORD CASUALTY INSURANCE COMPANY, administered by THE HARTFORD, Defendants

ADJ number: ADJ16635028
Decision date: Oct 12, 2025
District office: Long Beach
WCJ: —
Claim administrator: The Hartford (Hartford Casualty Insurance Company)
Commissioners: KATHERINE A. ZALEWSKI, CHAIR, KATHERINE WILLIAMS DODD, COMMISSIONER, JOSÉ H. RAZO, COMMISSIONER

Injury / body parts: psyche

LC §5909LC §5900LC §5313LC §5813CCR §10875CCR §10421CCR §10888CCR §10832CCR §10515

Summary

Lien claimant Premier Psychological Services failed to appear at a December 5, 2024 lien conference due to a clerical scheduling error. The WCJ first dismissed the lien without a hearing despite a timely objection; the Appeals Board rescinded that dismissal and remanded for a record-based decision under Labor Code section 5313. On remand, the WCJ issued a notice of intention to impose sanctions and set a combined hearing, but after the parties took the lien conference off calendar following settlement, the WCJ imposed sanctions without ever holding the hearing. The Board granted reconsideration, rescinded the sanctions order, and again remanded, holding that imposing sanctions without an evidentiary hearing on the reasonableness of the failure to appear deprived the lien claimant of due process.

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.

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.