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PanelMed-legalLienDenied

Angela Derby — ADJ3309119

ANGELA DERBY, Applicant vs. CITY OF LOS ANGELES; permissibly self-insured, administered by ACCLAMATION, Defendants

ADJ number: ADJ3309119
Decision date: Aug 23, 2026
District office: Van Nuys
WCJ: —
Claim administrator: Acclamation Insurance Management Services (for permissibly self-insured City of Los Angeles)
Commissioners: CRAIG L. SNELLINGS, COMMISSIONER, PAUL F. KELLY, COMMISSIONER, KATHERINE WILLIAMS DODD, COMMISSIONER

LC §5909LC §5900LC §4903LC §4903.05LC §4903.06LC §4603.6LC §4610.5LC §4610LC §4600LC §1317.1CCR §10600

Summary

Lien claimant Lien On Me, Inc. filed a medical-legal lien on November 14, 2012, prior to January 1, 2013, and paid an activation fee under Labor Code section 4903.06, but never filed the declaration required by section 4903.05(c). The WCJ dismissed the lien, and lien claimant petitioned for reconsideration arguing that liens subject to the activation fee were exempt from the declaration requirement. The Board rejected this argument, holding that the legislative intent behind SB 1160 was to impose the declaration requirement on all lien claimants as an anti-fraud measure, and that the filing fee and activation fee serve the same purpose of deterring frivolous liens. The Board denied the Petition for Reconsideration, following Montelongo and subsequent panel decisions.

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.