WCPanelIQ
PanelDenied

Crater, Barbara

BARBARA CRATER, Applicant vs. CRATE & BARREL HOLDINGS INC; PROPERTY & CASUALTY COMPANY OF HARTFORD, administered by SEDGWICK CLAIMS MANAGEMENT SERVICES, Defendants

ADJ number
ADJ17825300
Decision date
Sep 21, 2025
District office
Santa Ana
WCJ
—
Claim administrator
Sedgwick Claims Management Services (administering for Property & Casualty Company of Hartford)
Commissioners
KATHERINE WILLIAMS DODD, COMMISSIONER, CRAIG SNELLINGS, COMMISSIONER, KATHERINE A. ZALEWSKI, CHAIR

Injury / body parts: head, brain, psyche, heart (claimed), sleep (claimed)

LC §5909LC §5900LC §5813LC §4600CCR §9767.12

Summary

Applicant Barbara Crater, a furniture salesperson, sustained injury to her head, brain, and psyche on May 15, 2022, when she tripped and hit her head, resulting in a subdural hematoma and cognitive injury. Her treating physician requested 28 hours per week of home care for six months, which defendant authorized through utilization review. The dispute centered on whether defendant could assert MPN control over the selection of the home caregiver and whether applicant could select a family member (her daughter) to provide that care. The WCJ found that defendant failed to prove the existence of an approved and enforceable MPN providing ancillary services, that there was no MPN control over caregiver selection, and that applicant had the right to select her daughter as home care provider. The Appeals Board denied defendant's Petition for Reconsideration, finding no error in the WCJ's determinations.

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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