WCPanelIQ
PanelGranted

Palacios, Mario

MARIO PALACIOS, Applicant vs. PLAN B ADVANTAGE, INC.; STATE COMPENSATION INSURANCE FUND, Defendants

ADJ number
ADJ17371801
Decision date
Oct 9, 2025
District office
Long Beach
WCJ
—
Claim administrator
State Compensation Insurance Fund
Commissioners
LISA A. SUSSMAN, DEPUTY COMMISSIONER, KATHERINE WILLIAMS DODD, COMMISSIONER, KATHERINE A. ZALEWSKI, CHAIR
LC §5003LC §3206.5LC §3201CCR §10955CCR §10964

Summary

Applicant Mario Palacios filed a petition for removal challenging a WCJ's August 4, 2025 order requiring him and two witnesses who signed a Compromise and Release (C&R) to appear in person at a hearing. Applicant argued the appearance could be accomplished remotely and sought guidance on the validity of electronic signatures on a C&R. The Appeals Board granted removal, finding that an in-person order would be legally incorrect and irreparable on reconsideration. Relying on its en banc Perez v. Chicago Dogs decision, the Board rescinded the in-person order and substituted an order permitting applicant to appear electronically to verify his signature. The Board also noted the witnesses could not be ordered to appear because they were not served and not in the official address record, and declined to issue an advisory opinion on electronic signatures while pointing parties to Civil Code section 1633.7 and Labor Code section 3206.5.

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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