Brianna Davis worked as an EMT at Tri-City Medical Center. On May 15, 2018, she injured her back, neck, and legs on the job and filed a workers’ compensation claim. After a period of modified duty, Dr. Patrick O’Meara evaluated her in February 2019 and concluded she was not disabled, leading to her return to full duty in March 2019. Davis alleged she continued to suffer pain throughout, and on May 25, 2019, performing chest compressions for more than two hours caused a second industrial injury, for which she filed a new workers’ compensation claim.

Davis alleged that Corvel Corporation — the workers’ compensation claims administrator hired by Tri-City — and Corvel claims adjuster Rob Maag pressured Dr. O’Meara to falsify his medical findings so that Corvel could deny her benefits. Critically, Davis alleged that in a July 2019 medical report, Dr. O’Meara stated he had physically examined her when he had not, then falsely concluded she had reached maximum medical improvement and needed no work restrictions. She also alleged that Maag pressured a second physician, identified only as “Dr. M.,” to produce similar findings, and that when Dr. M. refused, Maag and others stopped referring patients to him. A third physician, Dr. Clarence Lee, allegedly refused to complete Davis’s disability paperwork for the California Employment Development Department due to pressure from the defendants.

Based on these allegations, Davis sued Corvel, Maag, and Dr. O’Meara for fraud and deceit under Civil Code sections 1709 and 1710, violations of the Unfair Competition Law (Bus. & Prof. Code § 17200 et seq.), and conduct she characterized as a RICO violation under 18 U.S.C. section 1962(c). The case reached the trial court on Davis’s third amended complaint — her fourth attempt at pleading viable claims.

The trial court sustained demurrers filed by Corvel, Maag, and Dr. O’Meara without leave to amend and dismissed the claims against them. The court found that all of Davis’s alleged injuries arose from the workers’ compensation claims process — specifically, disputes over the extent of her injury and the appropriate level of treatment — and were therefore barred by the exclusivity provisions of the California Workers’ Compensation Act (WCA; Lab. Code § 3200 et seq.). The court rejected Davis’s argument that fraud-based conduct places claims outside the WCA’s reach, finding that allegations of improper denial or limitation of benefits, even if framed as a conspiracy or tortious scheme, remain squarely within the compensation bargain. The court also found that the RICO allegations failed because the TAC did not allege facts showing conduct affecting interstate commerce or a pattern of continuing racketeering activity. Dr. Lee, who did not demur, was not part of the dismissal.

The Fourth District Court of Appeal affirmed the dismissal in full in the unpublished case of Davis v. Corvel Corporation et al., Case No. D085457 (April 2026).  The court conducted a de novo review — the standard applicable when a demurrer has been sustained — and independently concluded that Davis’s claims fell within the WCA’s exclusivity bar. The appellate court also declined to grant further leave to amend, noting that Davis had already been allowed three rounds of amendments and offered no new facts or theories on appeal that could cure the deficiencies. The opinion was not certified for publication.

The workers’ compensation exclusivity doctrine is broad. The court traced the two-step analytical framework established by the California Supreme Court. First, courts ask whether the alleged injury falls within the scope of the WCA’s exclusive remedy provisions — meaning whether it is “collateral to or derivative of” a compensable workplace injury. Second, if it does, courts ask whether the acts or motives behind the claim fall outside the risks encompassed by the compensation bargain, such as by violating a fundamental policy of the state. Citing Vacanti v. State Comp. Ins. Fund (2001) 24 Cal.4th 800, 811–812, and King v. CompPartners, Inc. (2018) 5 Cal.5th 1039, 1051–1052, the court emphasized that the WCA covers not just the original workplace injury but all injuries stemming from the claims process itself, including wrongful delays or denials of benefits.

Fraud in the claims process is not enough to escape exclusivity. Davis argued that Dr. O’Meara’s false medical reports constituted “outright fraud” placing her claims outside the WCA — analogizing to cases where an insurer fraudulently denied the very existence of an insurance policy, or where an employer concealed a workplace hazard. The court rejected both analogies. Citing Jablonski v. Royal Globe Ins. Co. (1988) 204 Cal.App.3d 379, it distinguished cases involving denial of a policy’s existence from cases involving disputed benefit levels, finding the latter to be a normal part of the WCA process. It similarly distinguished Johns-Manville Products Corp. v. Superior Court (1980) 27 Cal.3d 465, which involved concealment of a known occupational hazard from employees who were unaware of both the danger and their rights. Davis, by contrast, was aware of her injuries and her WCA rights throughout. What she alleged, at bottom, was that her benefits were improperly limited — a dispute the WCA process is designed to resolve.

Individual capacity and treating-physician status did not help. Davis argued that Maag was personally liable because he was sued individually rather than in his corporate role. The court rejected this, finding that Maag’s conduct — pressuring physicians to alter reports on Corvel’s behalf — was unambiguously part of the claims administration process. Citing Mitchell v. Scott Wetzel Services, Inc. (1991) 227 Cal.App.3d 1474, 1479, the court noted that even intentional refusal to pay benefits, with full knowledge of the hardship caused, does not avoid WCA exclusivity. As to Dr. O’Meara, Davis invoked the dual capacity doctrine from Duprey v. Shane (1952) 39 Cal.2d 781, which allows a physician to be sued in tort for negligently aggravating a patient’s injury through treatment. The court found Duprey inapplicable: Davis was not alleging a new physical injury caused by negligent medical care, but rather that falsified reports caused her to lose benefits. That is a claims-process injury, not a treatment injury — and the WCA provided a remedy she could have pursued before the Workers’ Compensation Appeals Board.