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PanelMed-legalLienGranted in Part

Orozco, Patricia

PATRICIA OROZCO, Applicant vs. CENTRAL CALIFORNIA CHILD DEVELOPMENT SERVICES; PROCENTURY INSURANCE COMPANY, administered by ILLINOIS MIDWEST SPRINGFIELD, Defendants

ADJ number: ADJ13806639
Decision date: Oct 5, 2025
District office: Fresno District Office
WCJ: —
Claim administrator: Illinois Midwest Springfield (administering ProCentury Insurance Company)
Commissioners: JOSÉ H. RAZO, COMMISSIONER, ANNE SCHMITZ, DEPUTY COMMISSIONER, CRAIG L. SNELLINGS, COMMISSIONER

Injury / body parts: multiple body parts

LC §4622LC §4602LC §4603.3LC §4603.6LC §4620LC §4621LC §4902LC §5705LC §5800LC §5811LC §5814LC §5814.5LC §5900LC §5904LC §5909CCR §10600CCR §10786

Summary

Applicant's former attorney Kenneth Mackie, who had fronted the cost of a vocational expert evaluation, sought reimbursement of $3,675.00 plus penalties under Labor Code section 4622(a)(1) and interest. The WCJ awarded the costs and interest but deferred penalties until the end of the case in chief. Mackie sought review, arguing penalties were mandatory once full costs were awarded. The Board granted reconsideration, holding that section 4622 penalties are designed to protect the actual medical-legal provider, not an attorney who merely paid for the services, so Mackie lacked standing to claim them. The Board affirmed the cost award but amended the order to also defer interest, finding the interest claim premature and that the proper statutory framework is sections 5811 (costs), 5800 (interest), and 5814/5814.5 (penalties), with any section 5814 penalty belonging to the applicant.

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.