Universal Psychiatric Med. Center v. WCAB
Champion Medical Group, a California Corporation doing business as Universal Psychiatric Medical Center, Inc. (Universal), was one of many lien claimants represented by Premier Medical Management Systems, Inc. (Premier). Universal assigned some of its liens to Premier for purposes of collection. As part of a plea bargain that resolved criminal charges against two of Premier’s executives, Premier dismissed the lien claims of 109 entities, Universal’s included. The workers’ compensation administrative law judge (WCJ) upheld the dismissal of Universal’s claim over its objections and the Workers’ Compensation Appeals Board (WCAB) denied Universal’s petition for reconsideration without issuing an opinion of its own.
The fundamental flaw in the WCJ’s reasoning is that the WCJ analyzed and addressed issues that were common to most of the lien claimants, whom the parties have chosen to designate collectively as the Premier Providers, and that the WCJ ignored the facts that were unique to Universal’s case. That is, the WCJ validated the resolution of the global case involving over 100 Premier Providers but failed to address Universal’s case. As it turns out, there is evidence that Universal did not authorize Premier to dismiss its liens. Concomitantly, the entire body of evidence on which the WCJ relied to find that Universal did authorize Premier to dismiss its liens is irrelevant to Universal, however relevant it may be to the Premier Providers. In fact, there is evidence that Universal cannot be included in the class of Premier Providers.
If the evidence is irrelevant, and is hence inadmissible,[1] the decision of the WCAB cannot be, and is not, supported by substantial evidence. Therefore, we annul the WCAB’s decision and remand with directions to vacate the dismissal of Universal’s liens. (Lab. Code, § 5952, subd. (d).)[2]
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