WCPanelIQ
PanelGranted in Part

Wilson, Kristan

KRISTAN WILSON, Applicant vs. HOLLINS MANAGEMENT GROUP, INC.; OLD REPUBLIC INSURANCE COMPANY, administered by GALLAGHER BASSETT SERVICES, Defendants

ADJ number
ADJ17142839
Decision date
Oct 20, 2025
District office
San Bernardino
WCJ
—
Claim administrator
Gallagher Bassett Services (administering for Old Republic Insurance Company)
Commissioners
KATHERINE WILLIAMS DODD, COMMISSIONER, ANNE SCHMITZ, DEPUTY COMMISSIONER, JOSEPH V. CAPURRO, COMMISSIONER
LC §5311LC §5903LC §5952LC §5313CCR §10960CCR §10955CCR §10761CCR §10759

Summary

Applicant Kristan Wilson sought disqualification of the WCJ, alleging the WCJ handed her attorney a dismissal form to obtain her signature, issued a notice of intent to dismiss, and made comments indicating bias. The underlying dispute involved applicant's December 16, 2024 petition for a protective order to exclude defendant's employer witness from a deposition, based on allegations the witness had assaulted her and put a gun in her mouth in front of her child. The WCJ proceeded as if the protective order petition was denied without conducting any evidentiary hearing or creating a record. The Board denied disqualification, finding the WCJ's statements were likely inartful references to prior status conferences rather than evidence of fixed bias, but granted removal because the trial was ordered off calendar without a record, violating due process. As its Decision After Removal, the Board rescinded the July 7, 2025 Minutes of Hearing and returned the matter to the trial level for a hearing on the protective order request.

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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