WCPanelIQ
PanelMed-legalLienGranted

Fernando Galindo — ADJ16889988

FERNANDO GALINDO, Applicant vs. PLATE LINE FRAMERS, INC.; STATE COMPENSATION INSURANCE FUND, Defendants

ADJ number
ADJ16889988
Decision date
Apr 20, 2026
District office
Oakland
WCJ
—
Claim administrator
State Compensation Insurance Fund
Commissioners
JOSÉ H. RAZO, COMMISSIONER, LISA A. SUSSMAN, DEPUTY COMMISSIONER, CRAIG L. SNELLINGS, COMMISSIONER

Injury / body parts: shoulder, arm, circulatory system, psyche

LC §5811LC §5813LC §5000LC §5001LC §5002LC §5003LC §4616LC §4622LC §4603.3LC §4603.6LC §5909LC §5900LC §5903LC §5952LC §5450LC §9793CCR §10545CCR §9795.3CCR §10421CCR §10786CCR §10510CCR §10803CCR §9793

Summary

Cost petitioner NAP Interpreting provided certified Spanish interpretation services for applicant Fernando Galindo at the reading and signing of a Compromise & Release on March 14, 2024, and billed $375.00. SCIF initially denied the invoice on the improper basis that an MPN interpreter was not used, mistakenly applying the medical provider network rule under section 4616 to an interpreter cost under section 5811. SCIF did not pay the invoice until June 16, 2025—15 months after receiving it and 90 days after the cost petition was filed. The WCJ found no bad faith, characterizing the non-payment as a 'bureaucratic screw up,' and declined to award sanctions or attorney fees. The Appeals Board granted reconsideration, rescinded the F&O, and found that SCIF acted in bad faith and/or employed tactics solely intended to cause unnecessary delay, ordering mandatory sanctions of not less than $500.00 plus attorney fees, with the amounts to be determined on remand.

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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