WCPanelIQ
PanelGranted in Part

Patrick Owens — ADJ14802723

PATRICK OWENS, Applicant vs. NORTHROP GRUMMAN CORP.; AMERICAN HOME ASSURANCE COMPANY, administered by SEDGWICK CMS, Defendants

ADJ number
ADJ14802723
Decision date
Jun 28, 2026
District office
San Jose
WCJ
—
Claim administrator
Sedgwick CMS (administering for American Home Assurance Company)
Commissioners
ANNE SCHMITZ, DEPUTY COMMISSIONER, JOSEPH V. CAPURRO, COMMISSIONER, JOSÉ H. RAZO, COMMISSIONER
LC §5903LC §5952LC §5313CCR §10955CCR §10813CCR §10761

Summary

Applicant Patrick Owens filed both a petition for disqualification and a petition for removal challenging the WCJ's April 23, 2026 order setting his 132a petition for trial together with a petition to seal various medical records. Applicant argued the sealing issue should be resolved before the 132a trial and that the WCJ was biased. The WCJ voluntarily recused herself, mooting the disqualification issue, and recommended denial of removal. The Board found the WCJ failed to follow WCAB Rule 10813 (Cal. Code Regs., tit. 8, § 10813) governing the sealing of documents, which requires referral to the presiding judge and due process. The Board dismissed the disqualification petition as moot, granted removal, rescinded the trial-setting order, and returned the matter to the presiding judge to first address the petition to seal before reassigning to a new trial judge.

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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