WCPanelIQ
PanelQMELienDenied

Lewis Williams — ADJ16112682

LEWIS WILLIAMS, Applicant vs. VOLT WORKFORCE SOLUTIONS, AIU INSURANCE COMPANY, administered by GALLAGHER BASSETT, Defendants

ADJ number
ADJ16112682
Decision date
May 18, 2026
District office
Oakland
WCJ
James Griffin
Claim administrator
Gallagher Bassett (administering AIU Insurance Company)
Commissioners
—

Injury / body parts: bilateral shoulders, left knee

LC §4663LC §4664LC §5806LC §5807LC §5813LC §5900LC §5902LC §5909CCR §10390CCR §10400CCR §10401CCR §10421CCR §10510CCR §10945

Summary

Defendant sought reconsideration of a WCJ's February 13, 2026 Findings, Award, and Order finding applicant Lewis Williams sustained 76% permanent disability without apportionment to his bilateral shoulders and left knee. The WCJ rejected QME Dr. Hughes' apportionment determinations because the doctor merely referenced 'some pre-existing degenerative changes' without explaining the 'how and why' required by Escobedo v. Marshalls. The defendant's petition was unsigned and unverified, and raised the need for further development of the record and a supplemental QME report for the first time on reconsideration. The Appeals Board found grounds to dismiss for lack of verification but instead denied the petition on the merits, adopting the WCJ's reasoning. The Board also issued extensive admonitions to defense counsel regarding failure to properly identify liable entities under Coldiron and DiFusco.

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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