Gregg Rader sustained an industrial injury to his psyche in the form of emotional stress while employed by Ticketmaster Corporation, with dates of injury spanning from November 12, 1991 through November 12, 1992. On January 19, 2011, a Workers' Compensation Judge approved the parties' Stipulations with Request for Award, granting Rader an award of 100 percent permanent total disability at a weekly rate of $336.00. As part of that award, the WCJ approved an attorney's fee of $39,444.71 — calculated as 15 percent of the present value of Rader's anticipated lifetime benefits of $262,964.75 (after a 3% present value reduction). To fund this fee, the parties agreed to commute it laterally from Rader's weekly benefits, reducing each payment by $50.40 and yielding a net weekly payment of $285.60. Years later, Rader contended that the total amount withheld from his weekly benefits had fully satisfied the $39,444.71 attorney's fee. His math was straightforward: dividing $39,444.71 by $50.40 per week produced roughly 782.63 weeks, which — counted from the initial payment date of June 6, 2008 — pointed to approximately June 5, 2023 as the date the commutation should have ended. He argued that his weekly rate should have returned to the full $336.00 at that point and sought penalties and interest for the continued withholding. Defendant State Compensation Insurance Fund (SCIF) countered that the award was silent on any end date for the commutation and that the WCAB lacked jurisdiction to alter the award. The WCJ sided with SCIF. The WCJ reasoned that imprecision is inherent in life-expectancy estimates and that the gross amount of weekly reductions exceeding the fee amount was simply the expected outcome when an applicant outlives the projected life expectancy. The WCJ further found that under Labor Code section 5804, the attempt to undo the rate reduction was filed many years outside the permissible five-year window for amending an award, and therefore the court lacked jurisdiction. Last January, the WCAB granted Rader's Petition for Reconsideration in the Significant Panel Decision of Gregg Rader v Ticketmaster -ADJ7138762 (January 2026) and substitute new Findings of Fact that the WCAB retains ongoing jurisdiction over the award of attorney’s fees pursuant to section 5803, and that because defendant has taken credit from applicant’s weekly payment of permanent indemnity in an amount equivalent to the dollar amount of commuted attorney’s fees, applicant is thereafter entitled to the full amount of his award without further reduction for attorney’s fees. The State Fund was now the aggrieved party in the case for the first time, thus it was allowed to filed its own Petition for Reconsideration. The WCAB just denied SCIF's petition for reconsideration in the second panel decision of Rader v. Ticketmaster Corporation -ADJ7138762 (April 2026), affirming its own January 8, 2026 Opinion and Decision After Reconsideration (ODAR) which has been deemed a Significant Panel Decision. That earlier decision had revIersed the WCJ, holding that the WCAB retains jurisdiction over the dispute and that the weekly commutation ends once the gross amount of the awarded attorney's fee ($39,444.71) has been fully satisfied — after which Rader is entitled to his full $336.00 weekly rate. On Jurisdiction: The WCAB acknowledged that Labor Code section 5804 bars rescission, alteration, or amendment of an award more than five years from the date of injury. However, the Board drew a critical distinction: this dispute concerned the enforcement of the existing award's terms — specifically, the allocation of attorney's fees — rather than an alteration of the underlying disability award itself. Under Labor Code section 5803, the WCAB retains ongoing jurisdiction to enforce its orders and awards, including matters collateral to the award such as commutations and attorney's fees. Relying on Hodge v. Workers' Comp. Appeals Bd. (1981) 123 Cal.App.3d 501, 508-509 [46 Cal.Comp.Cases 1034], the Board emphasized that commutation merely alters the form of an award and does not affect the merits of the basic decision determining the worker's right to benefits. On the Merits: The WCAB examined the actual language of the Stipulations and Award and found that the only basis for withholding was to satisfy the specified attorney's fee lien of $39,444.71. Neither the Stipulations nor the Award authorized withholding for any other purpose or contemplated an indefinite reduction. The Board reasoned that once a lien is fully paid, no statutory basis exists to continue allowing it as a charge against compensation under Labor Code section 4903(a). Additionally, under Labor Code section 5100, all commutations must avoid inequity and undue hardship to the applicant — and continuing to reduce benefits for attorney's fees that have already been fully satisfied would be manifestly inequitable. On SCIF's Commutation Table Argument: SCIF pointed to Examples D and E in the commutation instructions under Administrative Director Rule 10169.1 (Cal. Code Regs., tit. 8, § 10169.1), which provide that after commutation of all remaining life pension indemnity, no further benefits are due. The WCAB found these examples inapposite because they involve commuting the entirety of an applicant's future benefits, whereas here the parties commuted only a fixed dollar amount of attorney's fees from an ongoing lifetime benefit stream. A Remaining Open Question: While affirming that the commutation must end once the fee amount is satisfied, the WCAB expressly declined to opine on whether the present-value equivalent of the fees had already been fully withheld — noting that such a determination may require expert testimony and proper application of the 3% present-value calculations under AD Rules 10169 and 10169.1. The Board encouraged the parties to resolve the issue amicably but reminded them that any further proceedings must be supported by substantial evidence in the record, citing Hamilton v. Lockheed Corporation (2001) 66 Cal.Comp.Cases 473, 478 (Appeals Bd. en banc) ...

A U.S. District Judge sentenced Felipe Ruiz, 52, of Fresno, and Jose Gabriel Aguirre, 53, of Clovis, to 63 months in prison for conspiracy to commit health care fraud. The Judge also ordered forfeiture of nine properties owned by Aguirre and Ruiz, as well as a $2.6 million personal forfeiture money judgement against Aguirre and a $12.1 million personal forfeiture money judgement against Ruiz. According to court documents, Ruiz was a podiatrist and the sole owner of West Coast Podiatry Inc. (WCP), a podiatric medical practice with locations in Fresno, Madera, and Stanislaus Counties. Aguirre was a pharmaceutical sales representative who sold skin grafts to Ruiz and WCP. Aguirre was not licensed to practice medicine. Between June 2021 and January 2024, Ruiz purchased skin grafts from Aguirre and permitted Aguirre to apply skin grafts and perform other medical procedures on patients suffering from severe wounds, including foot amputations. Application of the skin grafts required sharp debridement, which means using a scalpel to scrape the wound until it bleeds. Some patients believed Aguirre was a physician, referring to him as “Dr. Gabe.” Aguirre would perform medical procedures alone without supervision from a trained physician. Ruiz and Aguirre submitted fraudulent claims to Medicare, Medicaid, and Medi-Cal that falsely represented that Ruiz and other physicians had performed the medical procedures, such as applying skin grafts to patients, when Aguirre had actually rendered the services. In one example, WCP submitted $150,000 in claims to Medicare in 2023, claiming a physician performed the procedures, when in fact the physician was out of the country on vacation. In another example, Aguirre cut into patients with recently amputated feet with a scalpel and apply skin grafts without a physician’s supervision. Ruiz knew about Aguirre’s conduct and dismissed staff’s concerns about Aguirre. Throughout the period, staff and third-party auditors raised concerns about Ruiz and Aguirre’s billing practices. The two ignored those warnings and continued to bill Medicare and Medicaid for services performed by Aguirre. As a result, Ruiz submitted approximately $3,200,000 in false claims to Medicare, Medicaid, and Medi-Cal between 2021 and 2024. The U.S. Department of Health and Human Services Office of Inspector General and the Federal Bureau of Investigation conducted the investigation. Assistant U.S. Attorneys Brittany M. Gunter and Cody S. Chapple prosecuted the case ...

Jeanette France worked as an occupational health nurse for the Los Angeles Department of Water and Power (DWP), first through a staffing agency from June to September 2016, and then as a direct hire under an emergency appointment beginning September 27, 2016. Emergency appointments under the Los Angeles City Charter are temporary, capped at one year, and may be terminated at any time without cause. France's immediate supervisor was Bedros Okhanes, who reported to medical director Dr. Leslie Michelle Israel. On January 9, 2017, France was injured at work when a chair she was sitting in fell, causing injuries to her lower back and shoulder. The next day she reported the injury and filed a workers' compensation claim. On February 1, 2017 — less than a month after the injury — the DWP terminated her employment. France described a sequence of events that day: she was first called to the workers' compensation office, where she met with Okhanes and two workers' compensation staff members who asked her to sign documents. France told them she had retained a lawyer — something she had not previously disclosed. Ten to fifteen minutes later, she was called into Dr. Israel's office, where the DWP's director of human resources, Deitra Barnett, told France she was fired without explanation. The DWP maintained that France was terminated for poor job performance that predated her injury. Dr. Israel identified several concerns: France failed to check patient identification before administering vaccines, left vaccines unrefrigerated, and did not take a patient's blood pressure before a breathing test. Okhanes, in a 2019 deposition (he passed away in 2022), confirmed that France had "problems with her assignments." Barnett testified that as an emergency hire, no written documentation of performance deficiencies was required before termination. France denied ever being spoken to about performance issues or receiving any discipline. She also pointed out that the DWP's internal termination paperwork listed no reason for her discharge. France pursued two tracks. First, she filed a civil lawsuit under the Fair Employment and Housing Act alleging disability discrimination and retaliation. In December 2019, the Los Angeles County Superior Court granted summary judgment for the DWP, finding under the burden-shifting framework of McDonnell Douglas Corp. v. Green (1973) 411 U.S. 792 that France was terminated for legitimate, nondiscriminatory reasons — namely, poor performance predating her injury — and that France failed to raise a triable issue of pretext. Second, France filed a workers' compensation petition alleging the DWP violated Labor Code section 132a, which prohibits employers from discharging employees for filing or threatening to file a workers' compensation claim. After a multi-day hearing, the workers' compensation judge denied the claim, finding that France failed to prove the termination was retaliatory in light of the performance evidence, and that she produced no evidence that those involved in terminating her even knew about her statements in the workers' compensation meeting minutes earlier. France sought reconsideration. The Workers' Compensation Appeals Board (WCAB) granted the petition, reversed the judge, and found the DWP had violated section 132a. The WCAB concluded the DWP failed to carry its burden of establishing good cause for termination, emphasizing the absence of written disciplinary records, the lack of a stated reason on termination paperwork, and the fact that Dr. Israel could not recall exact dates for the performance issues she observed. The Court of Appeal granted the DWP's petition for writ of review in the unpublished case of L.A. Department of Water & Power v. Workers' Compensation Appeals Board Case No. E086551 (April 2026) and annulled the WCAB's decision, directing the WCAB to reinstate the workers' compensation judge's original order denying France's section 132a claim. The court held that the WCAB's findings were unreasonable because the Board systematically ignored relevant evidence rather than evaluating the record as a whole. Citing Bracken v. Workers' Comp. Appeals Bd. (1989) 214 Cal.App.3d 246, 255, the court emphasized that while the WCAB has broad authority to make its own credibility determinations on reconsideration, it cannot meet the substantial evidence standard by isolating favorable evidence and ignoring contradictory facts. The court also relied on Lamb v. Workmen's Comp. Appeals Bd. (1974) 11 Cal.3d 274, 281 and Garza v. Workmen's Comp. App. Bd. (1970) 3 Cal.3d 312, 317 for the same principle. Specifically, the court identified several ways the WCAB mischaracterized the record. Both Barnett and Israel testified that France was terminated for poor performance, yet the WCAB found that no witness confirmed this. The WCAB stated Barnett testified France was terminated merely because the emergency appointment ended, but Barnett actually testified the appointment was ended because of poor performance. The WCAB discredited Israel's testimony because she could not recall specific dates for the performance issues, while ignoring the superior court's summary judgment order — part of the record — containing Israel's declaration placing those issues in October and November 2016, well before the injury. The WCAB faulted the absence of testimony from France's direct supervisor Okhanes without acknowledging his 2019 deposition testimony, which was in the record and was the only testimony available given his death in 2022. Finally, the WCAB drew negative inferences from the lack of written documentation without addressing Barnett's unrebutted explanation that emergency hires required no such documentation under the City Charter. The court stressed that the WCAB was free to weigh evidence and make credibility determinations, but it was not free to simply ignore evidence that cut against its conclusions. Because the WCAB's decision was not based on the entire record as required by Labor Code section 5952, the court annulled it under the standard set forth in Smith v. Workers' Comp. Appeals Bd. (2000) 79 Cal.App.4th 530, 535 and ordered reinstatement of the original award following Redner v. Workmen's Comp. Appeals Bd. (1971) 5 Cal.3d 83, 97 ...

Adrian Muñoz, 36 (born October 22, 1989, and a Los Angeles resident), formerly worked as a medical examiner investigator for the County of Los Angeles Medical Examiner’s office (previously the Department of Medical Examiner-Coroner) since 2018. On April 10, 2026, he pleaded no contest in Los Angeles Superior Court (case BA519016) to one felony count of grand theft and one misdemeanor count of petty theft. These charges involved stealing personal items from deceased individuals during death investigations he was assigned to handle. On January 6, 2023: Muñoz responded to the death of a warehouse worker in South Los Angeles who died of a heart attack on the job. Surveillance footage showed him removing a gold crucifix necklace from the deceased man’s neck and placing it in his medical bag. He did not return the item to the family or document it on the required property receipt. The warehouse worker was previously identified by his family as Miguel Solorio. They told the Los Angeles Times in 2023 that he had worn the necklace for decades.Solorio had been a roughly 10-year employee of Hylands, working in a warehouse where homeopathic products were loaded, unloaded, managed and shipped. Rosalba Solorio, Miguel’s daughter-in-law, who also worked at Hylands, said a representative of the district attorney’s office had called the family to tell them that Muñoz had been arrested. “We’re happy the investigation didn’t just fall through the cracks,” she said. “They actually did something about it and hopefully we’ll see justice for my father-in-law.” An employee of Hylands, who asked for anonymity for fear of retribution, told The Times that Muñoz had been called to take care of Solorio’s body. According to the employee, a security camera at the warehouse caught Muñoz removing the necklace from the body, placing it in a glove and then slipping it into his medical bag. The footage also showed Muñoz taking cash from the front pocket of the man’s pants and, again, slipping it into a glove in his medical bag. “There is something especially appalling about stealing from the dead. During a time when dignity and respect should be absolute, Mr. Muñoz chose greed,” Los Angeles County District Attorney Nathan J. Hochman said. “Today’s plea is a step toward justice, but it cannot undo the additional trauma inflicted on families who were already dealing with loss. Thank you to Deputy District Attorneys Brandy Chase and Kristopher Gay of the Justice System Integrity Division for their work to ensure the defendant was brought to justice.” Muñoz is scheduled to be sentenced June 5 in Department 113 of the Foltz Criminal Justice Center. Muñoz is expected to be sentenced to two years of formal probation, serve 180 days in Los Angeles County jail, permanently resign from the Peace Officer Standards and Training (POST) and pay restitution to each victim’s family. The case was prosecuted by Deputy District Attorneys Brandy Chase and Kristopher Gay and investigated by the Los Angeles County Sheriff’s Department ...

A San Fernando Valley woman was sentenced to 180 months in federal prison for her long-running drug dealing activities, including selling ketamine that contributed to at least two deaths, including the overdose death of actor Matthew Perry in October 2023. Jasveen Sangha, 42, a.k.a. “Ketamine Queen,” of North Hollywood, was sentenced by United States District Judge Sherilyn Peace Garnett. Matthew Langford Perry was an American and Canadian actor, comedian, director and screenwriter. He gained international fame for starring as Chandler Bing on the NBC television sitcom Friends (1994–2004). Perry also appeared on Ally McBeal (2002) and received Primetime Emmy Award nominations for his performances in The West Wing (2003) and The Ron Clark Story (2006). He played a leading role in the NBC series Studio 60 on the Sunset Strip (2006–2007), and also became known for his leading film roles in Fools Rush In (1997), Almost Heroes (1998), Three to Tango (1999), The Whole Nine Yards (2000), Serving Sara (2002), The Whole Ten Yards (2004), and 17 Again (2009). On October 28, 2023, Perry was found unresponsive in a hot tub at his home in Pacific Palisades. On December 15, 2023, Perry’s death was revealed to have occurred due to acute effects of ketamine. On August 15, 2024, indictments and charges were filed against five people: Perry’s personal assistant, two doctors, and two drug dealers (including TV director Erik Fleming), alleging involvement in the distribution of ketamine that caused the death of Perry and one other person. Sangha pleaded guilty in September 2025 to one count of maintaining a drug-involved premises, three counts of distribution of ketamine, and one count of distribution of ketamine resulting in death or serious bodily injury. Sangha is a dual citizen of the United States and the United Kingdom and has been in federal custody since August 2024. “For years…Sangha operated a high-volume drug trafficking business out of her North Hollywood residence,” prosecutors argued in a sentencing memorandum. “To cultivate her business, [Sangha] marketed herself as an exclusive dealer who catered to high-profile Hollywood clientele…While [Sangha] worked to expand and profit from her drug trafficking, she knew – and disregarded – the grave harm her conduct was causing.” According to court documents, Sangha worked with Erik Fleming, 56, of Hawthorne, to knowingly distribute ketamine to Perry, a successful actor and author whose struggles with drug addiction were well documented. In October 2023, Sangha and Fleming sold Perry 51 vials of ketamine, which were provided to Kenneth Iwamasa, 61, of Toluca Lake, Perry’s live-in personal assistant. Leading up to Perry’s death, Iwamasa repeatedly injected Perry with the ketamine that Sangha supplied to Fleming. Specifically, on October 28, 2023, Iwamasa injected Perry with at least three shots of Sangha’s ketamine, which caused Perry’s death. In August 2019, Sangha sold four vials ketamine to victim Cody McLaury, who died hours later from a drug overdose. In March 2024, law enforcement searched the residence and found thousands of pressed methamphetamine pills, 79 vials of liquid ketamine, MDMA (Ecstasy) tablets, counterfeit Xanax pills, baggies containing powdered ketamine and cocaine, and other drug trafficking items such as a gold money counting machine, a scale, a wireless signal and hidden camera detector, drug packaging materials, and $5,723 in cash. Sangha also used her North Hollywood residence to store, package, and distribute narcotics, including ketamine and methamphetamine, since at least June 2019. Besides Sangha, the following defendants have been sentenced in this case: - - Salvador Plasencia, 44, a.k.a. “Dr. P,” of Santa Monica, is serving a 30-month prison sentence after pleading guilty in July 2025 to four counts of distribution of ketamine. He surrendered his California medical license in September 2025. Plasencia repeatedly sold vials of ketamine to Perry despite knowing Perry’s well-documented history of drug addiction and that Perry’s personal assistant was administering the drug without medical training or supervision. - - Mark Chavez, 55, of San Diego, was sentenced to three years of probation, eight months of home detention, and was ordered to perform 300 hours of community service after he pleaded guilty in October 2024 to one count of conspiracy to distribute ketamine. Chavez operated a ketamine clinic and sold the drug to Plasencia, who then distributed it to Perry. Chavez surrendered his medical license in November 2024. Iwamasa and Fleming are scheduled to be sentenced in the coming months. Each of them pleaded guilty in August 2024 to federal narcotics charges ...

A San Fernando Valley man who operated corrupt medical clinics was sentenced to 216 months in federal prison for participating in a drug trafficking ring that sold thousands of illegal opioid prescriptions for cash. Justin Douglas Cozart, 48, of Woodland Hills, who operated and supervised the ChiroMed medical clinics, was sentenced by United States District Judge David O. Carter. In February 2025, at the conclusion of a five-day trial, a federal jury found Cozart guilty of one count of conspiracy to distribute and to possess with intent to distribute oxycodone, one count of conspiracy to launder monetary instruments, and one count of concealment money laundering. From 2017 to January 2020, Cozart and others knowingly and intentionally participated in a conspiracy to distribute the opioid painkiller oxycodone outside the usual course of professional practice and without a legitimate medical purpose. Cozart operated several medical clinics in Southern California. Other members of the conspiracy recruited sham patients to go to Cozart’s clinics – including ones in Inglewood, Santa Ana, and Anaheim – to obtain oxycodone prescriptions. Cozart employed doctors at the clinic, including John Korzelius, 74, a.k.a. “Dr. K,” of Long Beach, who wrote oxycodone prescriptions for the fake patients. The recruiters then paid Cozart for the fraudulent oxycodone prescriptions. Upon obtaining the prescriptions from the clinic, the recruiters took the sham patients to a pharmacy to fill the prescriptions. After collecting and consolidating the pills, co-conspirators shipped them to a drug customer in the Boston area, for distribution on the black market. On two occasions in October and December 2018, parcels containing their consolidated pills were seized by law enforcement. In November and December of 2019, at a clinic in Inglewood, Korzelius issued prescriptions for 60 30 milligram oxycodone pills – the highest dose of short-acting oxycodone available and the dose most popular among drug abusers – to a patient who actually was an undercover law enforcement officer. Korzelius did not conduct a physical examination of this “patient” and instructed the undercover officer to not fill the prescription at a large pharmacy such as Walmart or CVS. “[Cozart] was a primary, illegal source of supply of oxycodone, a dangerous and frequently abused drug, for an organization that was shipping thousands of pills across the country for sale,” prosecutors argued in a sentencing memorandum. “He converted otherwise lawful chiropractic clinics into drug trafficking businesses, and pulled their existing employees…into his scheme.” In total, prosecutors in this case have secured nine convictions. Korzelius pleaded guilty in February 2025 to one count of conspiracy to distribute oxycodone. His California medical license expired in December 2020. His sentencing hearing is scheduled for June 8 ...

An Orange County man has pleaded guilty to submitting nearly $270 million in fraudulent claims over an 11-month span to Medi-Cal for expensive prescription drugs containing generic ingredients that were not medically necessary and, in many instances, not provided to the purported recipients. Paul Richard Randall, 66, of Orange, pleaded guilty to one count of wire fraud committed while on release. He has been in federal custody since June 2025. According to his plea agreement, Randall, along with Kyrollos Mekail, 37, of Moreno Valley, and Patricia Anderson, 58, of West Hills, took advantage of Medi-Cal’s suspension of its requirement that health care providers obtain prior authorization before providing certain health care services or medications as a condition of reimbursement. The suspension of the prior authorization requirements was part of an ongoing transition of Medi-Cal’s prescription drug program to a new payment system. Through a business called Monte Vista Pharmacy, Randall and his co-schemers exploited Medi-Cal’s prior authorization suspension by billing Medi-Cal tens of millions of dollars per month for dispensing high-reimbursement, non-contracted, generic drugs through Monte Vista Pharmacy. Some prescription medications purportedly were to treat pain and included Folite tablets, a vitamin available over the counter. Normally, these high-cost reimbursement medications would have required prior authorization under Medi-Cal’s old payment system. Medication involved in this scheme was medically unnecessary, frequently was not dispensed to patients, and procured by kickbacks. From May 2022 to April 2023, Monte Vista billed Medi-Cal more than $269 million and was paid more than $178 million for 19 expensive, non-contracted drugs containing low-cost, generic ingredients that were not medically necessary, not provided, or both. Randall and others then laundered their illicit proceeds by transferring the proceeds of the Medi-Cal fraud scheme to a third party to pay kickbacks to Anderson, to promote the fraud scheme and to conceal and disguise the transfers from detection by law enforcement. Randall admitted in his plea agreement to transmitting by wire at least approximately $269,120,829 in false and fraudulent claims to Medi-Cal for purportedly dispensing the fraud scheme medications that Anderson prescribed, on which Medi-Cal paid at least approximately $178,746,556. United States District Judge Mark C. Scarsi scheduled an August 3 sentencing hearing, at which time Randall will face a statutory maximum sentence of 30 years in federal prison. Relatedly, Mekail pleaded guilty in August 2024 to two counts of health care fraud and awaits sentencing. Anderson is charged with two counts of health care fraud. The United States Department of Health and Human Services Office of Inspector General (HHS-OIG), the FBI, and the California Department of Justice are investigating this matter. Assistant United States Attorney Roger A. Hsieh of the Major Frauds Section and Trial Attorney Siobhan M. Namazi of the U.S. Department of Justice, Criminal Division, Fraud Section are prosecuting this case. Assistant United States Attorney James E. Dochterman of the Asset Forfeiture and Recovery Section is handling asset forfeiture matters in this case ...

The National Safety Council NSC, is America’s leading nonprofit safety advocate – and has been for over 110 years. As a mission-based organization, it works to eliminate the leading causes of preventable death and injury, focusing our efforts on the workplace and roadways. It seeks to create a culture of safety to not only keep people safer at work, but also beyond the workplace so they can live their fullest lives. According to a new NSC study, workers who use technology to prevent musculoskeletal disorders (MSDs) on the job report real benefits: reduced concern about injury, improved posture and greater awareness of risks that lead to pain and strain. This conclusion comes from new National Safety Council research that puts worker experience at the center of the conversation. The report, Frontline Worker Perceptions of MSD Prevention Technology, draws on an MSD Solutions Lab survey of more than 400 non-managerial workers across diverse industries, including manufacturing, construction, health care, and transportation and warehousing. The MSD Solutions Lab was established in 2021 with funding from Amazon (NASDAQ: AMZN). Nearly 70% of respondents said they experience job-related MSD symptoms. The research also shows that when the right technologies are implemented appropriately they can make a meaningful difference. “For too long, the conversation about MSD prevention technology has centered on employers and developers – not the workers using these tools every day," said Paige DeBaylo, Ph.D., director of the MSD Solutions Lab at NSC. "Employers are looking for different ways to make their workers' jobs safer and less physically demanding. Many report that these technologies improve safety, reduce strain and support overall job satisfaction. That's why NSC is focused on advancing solutions that help prevent injuries before they happen.” Innovations that provide direct physical support, such as exoskeletons and robots, were most strongly associated with reduced MSD symptoms. Monitoring technologies like wearable sensors and computer vision helped workers identify ergonomic risks and build safer work habits. Across all technology types, one factor consistently predicted better outcomes: When organizations involve workers in selecting and using these tools, results improve. This reflects a core NSC workplace safety principle — workers are not just recipients of safety solutions, they are essential partners in making them work. These findings build on the Council’s ongoing research and collaboration to advance solutions that protect workers. Learn more at nsc.org/msd ...

Chronic kidney disease affects over 35.5 million Americans, and roughly 800,000 suffer from end-stage renal disease (ESRD), which requires either a kidney transplant or regular dialysis. More than 80% of ESRD patients are unemployed and lack employer-sponsored insurance. Private insurers reimburse dialysis providers at rates well above Medicare, creating an incentive for providers to keep patients on private plans. The American Kidney Fund (AKF), a nonprofit charity, runs a Health Insurance Premium Program (HIPP) that helps ESRD patients pay insurance premiums regardless of whether they choose public or private coverage. AKF's largest donors are dialysis giants DaVita and Fresenius Medical Care, which together account for an estimated 80% of AKF's funding. When HIPP recipients carry private insurance, these providers benefit from higher reimbursement rates. In 2019, California enacted Assembly Bill 290 to address what the legislature viewed as providers exploiting the Affordable Care Act's preexisting-condition rules. AB 290 contained five key provisions: a Reimbursement Cap tying provider payments to Medicare rates if the provider donated to a charity like AKF; a Patient Disclosure Requirement forcing AKF to reveal assisted patients' names to insurers; a Financial Assistance Restriction barring AKF from conditioning aid on treatment eligibility; a Coverage Disclosure Requirement mandating that AKF inform patients of all available insurance options; and a Safe Harbor Provision giving AKF until July 1, 2020, to request an updated federal advisory opinion. AKF warned it would shut down California operations if AB 290 took effect. AKF, the providers, and individual patients sued. The United States District Court Central District of California granted partial summary judgment to each side. It struck down the Anti-Steering Provision, the Patient Disclosure Requirement, and the Financial Assistance Restriction as unconstitutional, but upheld the Reimbursement Cap, the Coverage Disclosure Requirement, and the Safe Harbor Provision. The court also found the unconstitutional provisions severable from the rest of the statute. The panel affirmed in part and reversed in part, ultimately invalidating most of AB 290 in the published case of Fresenius Medical Care Orange County, LLC v. Bonta, Nos. 24-3654, 24-3655, 24-3700 (9th Cir. Apr. 7, 2026) Reimbursement Cap — Reversed (unconstitutional). The court held that capping reimbursement only for providers who donate to charities like AKF burdens the First Amendment right to expressive association, triggering exacting scrutiny under Americans for Prosperity Foundation v. Bonta, 594 U.S. 595 (2021). California demonstrated a sufficiently important interest in preventing distortion of insurance risk pools, but the Cap failed narrow tailoring. The state could have directly regulated reimbursement rates for ESRD patients without conditioning the cap on charitable donations. The provision was also overbroad, sweeping in any healthcare provider making any donation. Patient Disclosure Requirement — Affirmed (unconstitutional). Because California's sole justification for this provision was enforcing the now-unconstitutional Reimbursement Cap, the requirement lacked any surviving governmental interest and violated the First Amendment. Financial Assistance Restriction — Affirmed (unconstitutional). The court agreed the restriction burdened AKF's right to choose its own beneficiaries. While California has a substantial interest in protecting vulnerable populations from abusive practices, see Washington v. Glucksberg, 521 U.S. 702, 731 (1997), the restriction's broad text eliminated AKF's ability to determine its patient population, far exceeding what narrow tailoring permits. Coverage Disclosure Requirement — Affirmed as constitutional but not severable. Under Zauderer v. Office of Disciplinary Counsel of the Supreme Court of Ohio, 471 U.S. 626 (1985), the requirement to inform patients of all coverage options compels only factual, uncontroversial information reasonably related to preventing consumer deception. However, the court found this provision failed volitional severability: since 90% of affected patients already carry public insurance, a standalone disclosure mandate — especially without the Anti-Steering Provision — could actually push patients toward private coverage, defeating the legislature's purpose. Safe Harbor Provision — Moot. The deadline for AKF to request an updated advisory opinion (July 1, 2020) passed without action, rendering the issue nonjusticiable ...

Workplace amputations, while less common than sprains, strains, and fractures, generate some of the most complex and expensive claims in the system. They frequently involve catastrophic injury designations, lifetime medical benefits, permanent total disability determinations, and extensive vocational rehabilitation. The prosthetic device itself is often one of the largest recurring cost items in the claim, as socket prostheses require periodic replacement, refitting, and repair throughout the injured worker's lifetime. New research presented at the 2026 Annual Meeting of the American Academy of Orthopaedic Surgeons (AAOS) in New Orleans is reshaping the conversation around prosthetic limb technology for amputees — and the implications for catastrophic workers' compensation claims are substantial. Three studies from Hospital for Special Surgery (HSS), the nation's top-ranked orthopedic hospital, presented findings on osseointegration, a surgical procedure in which a metal implant is anchored directly into the residual bone of an amputee, allowing a prosthetic limb to attach to the skeleton itself rather than to a traditional socket worn over the stump. The research challenges longstanding clinical assumptions about who should receive this procedure and when. For decades, the standard rehabilitation path after a limb amputation has been a socket-mounted prosthesis — an external cup that fits over the residual limb and connects to the artificial leg or arm. The socket approach is familiar, widely available, and covered by most insurers. But it is also plagued by well-documented problems. Studies indicate that up to three-quarters of lower-extremity amputees experience skin ulcers, excessive perspiration, poor fit, or pain where the residual limb meets the socket. Frequent refitting is common. The size and shape of the residual limb can fluctuate significantly in the first 12 to 18 months after surgery, leading to misalignment, balance problems, and falls. Many amputees eventually reduce how often they wear their prosthesis — or stop using it altogether. Osseointegration eliminates the socket entirely. A biocompatible titanium implant is surgically inserted into the residual bone — most commonly the femur (above-knee amputation) or tibia (below-knee amputation). Over time, the bone grows into the implant's surface, creating a permanent mechanical bond. The external prosthetic limb then clicks directly onto the implant through a small opening in the skin. Osseointegration is not new — the concept dates to the 1940s, and the first prosthetic applications were developed in Sweden decades ago. What is new is the pace at which the clinical evidence base is expanding, the range of patients being treated, and the emergence of custom 3D-printed implants that can accommodate more complex anatomies. With HSS, the University of Colorado Limb Restoration Program, and other leading centers actively publishing outcomes data, the procedure is moving from niche to mainstream orthopedic practice. The clinical advantages are significant. Patients with osseointegrated prosthetics report improved stability, better energy transfer during walking, and dramatically improved proprioception — the body's sense of where a limb is in space. Because the prosthesis connects directly to bone, vibrations from ground contact travel through the skeleton, giving the user a degree of sensory feedback that socket prostheses cannot provide. Patients describe being able to feel the ground beneath them again. HSS has performed more osseointegration surgeries than any other hospital in the United States — over 300 since 2017 — and its surgeons were the first in the country to use the procedure for below-knee amputations. The three AAOS 2026 presentations each addressed a different question: Femur vs. tibia outcomes. The first study compared safety and functional outcomes between patients who received osseointegration at the femur level and those who received it at the tibia level. Previously, there was limited published data comparing the two. The researchers found that both groups achieved significant improvements in patient-reported outcomes and prosthetic use, with comparable safety profiles. This finding broadens the pool of candidates who may benefit from the procedure. Timing of the procedure. The second study examined whether osseointegration should be performed at the same time as the initial amputation or reserved for patients who have already tried and failed with a socket prosthesis. Conventional clinical practice has generally required amputees to attempt socket-based rehabilitation first. The HSS researchers found that patients who underwent simultaneous amputation and osseointegration achieved mobility and quality-of-life gains comparable to those who had osseointegration after an existing amputation, with no significant difference in complications. The lead researcher stated that the findings support offering osseointegration at the time of amputation for well-informed patients who prefer to bypass the socket trial — a meaningful departure from the current standard of care. Custom 3D-printed implants. The third study reviewed early outcomes using custom-made, 3D-printed osseointegration implants for patients whose anatomy does not fit standard implant configurations. The custom implants avoided a complication known as intraoperative distal chip fracture, which can occur with off-the-shelf implants, and showed no loosening. Short-term functional outcomes were comparable to standard implants ...

The Ventura County District Attorney’s Office announced that Jonah Abraham Slatky (DOB 04/19/72), of Somis, has been charged with six counts of felony workers’ compensation insurance premium fraud, with an alleged loss of approximately $519,000 in premiums not paid. (Superior Court. Case: 2024010769) The complaint further alleges a special enhancement for losses exceeding $100,000, as well as aggravating factors including that the crime involved both attempted and actual taking, and was carried out with planning, sophistication, or professionalism. Slatky was the owner of Grand Custom, a rough framing construction business. The charges stem from a six-year period between July 2019 and July 2025, during which Slatky is alleged to have intentionally underreported employee payroll to his workers’ compensation insurance carrier to significantly reduce premium costs. He faces 6 counts of violation of Insurance Code 11880(a) – Insurance fraud Special allegations include PC 186.11(a)(1) – Excessive loss over $100,000, CRC 4.421(a)(9) – The crime involved an attempted and actual taking, CRC 4.421(a)(8) – The manner in which the crime was carried out indicates planning, sophistication, or professionalism. Each count represents a separate policy year in which Slatky allegedly reported having zero employees and zero payroll. The investigation revealed evidence that Slatky employed multiple workers on construction projects while paying them in cash, despite reporting no employees to his insurer. Financial records showed millions of dollars in business been used for payroll. If convicted, Slatky faces a maximum sentence of six years and four months in state prison. The enhancement, if found true, makes a prison sentence mandatory. Slatky was arraigned on March 27, 2026, where he pled not guilty to all charges and was released on his own recognizance. As a condition of release, he is prohibited from operating a business unless it is properly insured with workers’ compensation coverage. Slatky is scheduled for an early disposition conference on April 30, 2026, at 1:30 p.m. in courtroom 12 of the Ventura County Court. The case was investigated by the Ventura County District Attorney’s Office Bureau of Investigation and is being prosecuted by Senior Deputy District Attorney Joann Roth ...

Federal authorities arrested eight defendants last week in a sweeping enforcement action targeting health care fraud across Southern California and beyond. The cases, coordinated with the Vice President's Task Force to Eliminate Fraud, involved more than $50 million in fraudulent billing — with sham hospice companies at the center of most charges. The Hospice Schemes Five separate cases targeted operators of fraudulent hospice care facilities. The common playbook: enroll Medicare beneficiaries who weren't terminally ill, bill Medicare for services that were unnecessary or never provided, and pay kickbacks to recruiters and patients to keep the pipeline flowing. The largest hospice case involves Nita Palma, a thrice-convicted health care fraudster who allegedly opened three new hospice companies while out on bond awaiting trial for a previous hospice fraud case. She and her husband, Adolfo Catbagan, are charged with billing Medicare at least $4.8 million through those companies, with Catbagan serving as the nominal owner to evade Palma's exclusion from Medicare. Other hospice defendants include Lolita Minerd, a vocational nurse whose company had an 85% non-death discharge rate — nearly five times the national average — and billed Medicare over $9.1 million; psychologist Gladwin Gill and his wife Amelou, who allegedly laundered over $4 million in fraudulent proceeds through personal expenses; Evelyn Tindimobuna, charged with billing $3.8 million for sham hospice services; and Ivan Lauritzen, whose company's live discharge rate exceeded 75% and who allegedly forged a physician's signature on enrollment forms. Union Health Plan Fraud Three additional cases targeted a longshore workers' union health plan. In the largest, four defendants are charged with submitting $19 million in false claims for chiropractic and physical therapy services through a network of wellness centers. Separately, Idaho chiropractor Gregory Cartmell allegedly billed $9.1 million under a co-conspirator's credentials after being terminated from the plan. And Sonia Griffen is charged with submitting $4.9 million in fraudulent claims through her wellness center after it, too, was barred from the plan. Immigration Medical Fraud In a standalone case, Young Joo Ko was charged with running a scheme exploiting the green card medical exam process — preparing required immigration health forms without actual physician examinations. The defendants face penalties ranging from 10 to 20 years in federal prison depending on the charges. All are presumed innocent until proven guilty ...

Aya Healthcare Services is a travel-nursing agency that pairs nurses with hospitals. As a condition of employment, each nurse signs an arbitration agreement requiring that any employment-related disputes be resolved through arbitration rather than in court. The agreements also contain a delegation clause providing that an arbitrator — not a court — will decide any challenge to the validity of the arbitration agreement itself. Four former Aya employees — Laura O'Dell, Holly Zimmerman, Lauren Miller, and Hannah Bailey — filed a putative class action against Aya, alleging that the company reduced their pay mid-contract. Their claims included breach of contract, fraudulent inducement, state wage-and-hour violations, and violations of the Fair Labor Standards Act. Aya moved to compel arbitration, and the district court granted that motion. The four cases were sent to separate arbitrations, where each arbitrator first had to decide whether the underlying arbitration agreement was enforceable. The results were split down the middle: two arbitrators found the agreements unconscionable due to one-sided fee and venue provisions, while the other two found the agreements valid, reasoning that a savings clause cured any unconscionability. Meanwhile, 255 additional plaintiffs opted into the case under the FLSA's collective-action provision, 29 U.S.C. § 216(b). Aya moved to compel each of these new plaintiffs to arbitrate under their own individual agreements. Rather than send the 255 opt-in plaintiffs to individual arbitrations, the district court — now presided over by a different judge — raised the issue of collateral estoppel on its own initiative. After briefing, the court applied the doctrine of non-mutual offensive collateral estoppel: it gave preclusive effect to the two arbitral awards that had found the agreements unconscionable, while declining to credit the two awards that had upheld the agreements, reasoning that those favorable awards were not as "reasoned" or "thorough." The practical result was sweeping — all 255 separate arbitration agreements were declared unenforceable without any of those employees ever going to arbitration. The Ninth Circuit Court of Appeals reversed in the published case of O'Dell et al. v. Aya Healthcare Services, Inc., No. 25-1528 (9th Cir. April 2026). Writing for the panel, Judge Tung held that non-mutual offensive collateral estoppel cannot be used to preclude enforcement of arbitration agreements under the Federal Arbitration Act. The panel grounded its reasoning in the text and structure of the FAA, along with a line of Supreme Court precedent warning against judicial devices that undermine arbitration. First, the court looked to Section 2 of the FAA, which provides that arbitration agreements "shall be valid, irrevocable, and enforceable" except on grounds that exist for the revocation of any contract — such as fraud, duress, or unconscionability. The panel concluded that non-mutual offensive issue preclusion is not a "generally applicable contract defense" and does not constitute a "revocation" of a contract within the meaning of the statute. It is a procedural doctrine about relitigation, not a doctrine about defects in contract formation. Second, the court emphasized that Sections 3, 4, and 10 of the FAA envision a scheme in which agreements are enforced according to their terms, arbitrations proceed without interference, and awards are confirmed unless the process was tainted by fraud or corruption. Nowhere in that framework, the court found, did Congress contemplate that a non-mutual preclusion doctrine could derail an arbitration the parties had agreed to undertake. Third, the panel held that applying the doctrine violated the FAA's foundational principle that arbitration rests on consent. As the Supreme Court has stated, arbitration "is a matter of consent, not coercion." Stolt-Nielsen S.A. v. AnimalFeeds Int'l Corp., 559 U.S. 662, 681 (2010). Binding Aya and 255 employees to the conclusions of arbitrators in separate proceedings involving different parties rendered their own mutual consent meaningless. Finally, the court observed that the district court's approach effectively created a binding bellwether class action without any of the procedural safeguards that class certification requires — including adequate representation. Under the district court's logic, a single arbitral award could foreclose hundreds or thousands of individually negotiated arbitration agreements. The panel found this result "fundamentally at war" with the FAA, echoing Stolt-Nielsen, 559 U.S. at 684, and consistent with the Supreme Court's holdings in AT&T Mobility LLC v. Concepcion, 563 U.S. 333 (2011), Epic Systems Corp. v. Lewis, 584 U.S. 497 (2018), and Lamps Plus, Inc. v. Varela, 587 U.S. 176 (2019). The panel also rejected the plaintiffs' argument that Section 13 of the FAA — which gives confirmed arbitral awards the force of a court judgment — authorized the use of non-mutual preclusion, noting that incorporating a doctrine of non-mutuality that did not exist when the FAA was enacted in 1925 would effectively cause "the act to destroy itself." ...

The California Attorney General filed an amicus brief in Art Center Holdings, Inc., et al. v. WCE CA Art, et al., a case before the California Second District Court of Appeal, B338625. The case involves a dispute between a physician who owned a medical practice and a private equity-backed management services organization (MSO). The dispute arises from a "friendly PC" (professional corporation) model arrangement common in healthcare, where a physician-owned professional corporation (PC) contracts with a management services organization (MSO) for administrative and non-clinical support. The case involves WCE, a management services organization (MSO). Under a management services agreement, WCE provided management and administrative services to the Southern California Reproductive Center (SCRC), a California professional corporation providing women's health, reproductive, and fertility services. In 2019, the physicians and their affiliated companies sold a 51 percent stake in their fertility practice to WCE in exchange for immediate cash and deferred/contingent consideration. WCE and its affiliates were to provide non-clinical services in exchange for fixed percentage fees. After BC Partners acquired WCE in 2020, disputes arose. The plaintiffs alleged that WCE mismanaged the practice — under-collecting accounts receivable, causing staff departures, and underinvesting in equipment. They further alleged the MSO asked the PC to terminate some physicians, and when it refused, WCE terminated the Consulting Agreement as a pretext to change ownership of the PC. The plaintiffs moved for the appointment of a receiver. The trial court found that WCE had engaged in the unlicensed corporate practice of medicine by exercising undue control over SCRC. The court reasoned that because WCE had the contractual ability to remove Dr. Surrey from his position whenever they disagreed with his clinical decisions, WCE effectively had undue control over the physician-owner — it could replace any doctor-owner at will with one more compliant with its wishes. The heart of the case concerns whether specific contractual mechanisms in the "friendly PC/MSO" structure violated California's longstanding corporate practice of medicine (CPOM) doctrine. This doctrine (rooted in the Medical Practice Act, Business and Professions Code §§ 2000 et seq., Corporations Code §§ 13400 et seq., and related provisions) prohibits unlicensed corporations and non-physicians from directly or indirectly practicing medicine, owning medical practices, or exercising undue control over licensed physicians' clinical judgment, including decisions on hiring, firing, disciplining, or retaining physicians based on clinical matters. MSOs may provide administrative support but cannot control clinical operations or create "captive" PCs where nominal physician ownership masks corporate dominance. The AG frames this structure as a "captive PC" — one where the physician is the nominal owner on paper, but the MSO holds effective control through contractual leverage. The AG describes this as part of a broader pattern in which private equity-backed MSOs use continuity agreements, assignable options, and stock transfer agreements to maintain de facto ownership and control of medical practices while technically complying with the requirement that only licensed physicians own PCs. The AG concludes that the trial court correctly held that these captive PC arrangements violate California's CPOM laws, and urges the Court of Appeal to affirm that legal standard rather than adopting the more permissive frameworks proposed by either party. According to a May 2024 California Health Care Foundation report, private equity investment into health care totaled about $83 billion nationally and $20 billion in California in 2021. While the majority of overall private equity dollars has been directed at biotechnology and pharmaceuticals in recent years, private equity acquisitions of health care service providers (such as clinics, hospitals, and nursing homes) make up a significant portion of all private equity health care deals. In California, acquisitions of providers totaled $4.31 billion dollars between 2019 and 2023, and represented roughly a third of all deals. Available data, while limited, show that private equity has gained a small but meaningful ownership foothold among certain kinds of providers. Private equity firms now own approximately 8% of all private hospitals in the U.S. and approximately 6% of private hospitals in California. Higher charges, which are often passed along to patients, have been documented in clinics, hospitals, and nursing homes. Twenty-seven studies reviewed found 12 with a harmful impact on quality of care, nine found a mixed impact, and three found a neutral impact. One rigorous study found that private equity acquisitions led to an 11% higher mortality rate during short-term nursing home stays. This appellate case will scrutinize the "friendly PC" model commonly used by private equity firms to invest in physician practices. The case was part of a broader wave of scrutiny in California that ultimately led to the passage of SB 351 in October 2025, which codified prohibitions on the corporate practice of medicine and restricted private equity groups from interfering with physicians' clinical decision-making ...

Corinne Leshen sustained an industrial injury on June 16, 2009, while employed by the State of California Highway Patrol, resulting in hypertension, arteriosclerosis, and hypertensive cardiovascular disease. Southland Spine & Rehabilitation Medical Center provided medical treatment services and filed a lien for reimbursement on January 7, 2011, under Labor Code § 4903(b). Because the lien predated January 1, 2013, Southland paid a $100 activation fee under § 4903.06 on December 16, 2015. It later filed a declaration under § 4903.8(d) on October 16, 2018. The underlying case settled on April 9, 2019, via stipulations with request for award at 50% permanent disability. Critically, Southland never filed the supplemental lien declaration required by Labor Code § 4903.05(c)(2), which set a deadline of July 1, 2017 (extended to July 3, 2017, because July 1 fell on a weekend) for all medical treatment liens filed before January 1, 2017. The matter came on for lien trial on October 28, 2025, with jurisdiction and the declaration requirement as the issues in dispute. On December 18, 2025, the WCJ issued findings that Southland had failed to timely file the required declaration by July 3, 2017, resulting in dismissal of the lien by operation of law under § 4903.05(c)(3). The WCJ reasoned that § 4903.05(c)(2) unambiguously applied to all liens filed before January 1, 2017, for medical treatment expenses under § 4903(b), regardless of whether those liens were subject to a filing fee or an activation fee. The WCAB panel denied Southland's petition for reconsideration and affirmed the WCJ's dismissal of the lien in the panel decision of Leshen v. State of California Highway Patrol, ADJ6925586 (March, 2026) Southland argued that because its 2011 lien was subject to the activation fee under § 4903.06 rather than the filing fee under § 4903.05, the declaration requirement of § 4903.05(c) did not reach its lien. The Board rejected this reading. Drawing on the panel decision in Montelongo v. Gelson's Market (February 11, 2022, ADJ2193346) [2022 Cal. Wrk. Comp. P.D. LEXIS 41], the Board traced the legislative history of SB 1160 (2016), which added the declaration requirement to § 4903.05(c). The Legislature expressly described the declaration as an "anti-fraud" measure intended to apply to "all lien claimants," requiring each to identify the specific statutory basis authorizing its lien. SB 1160's floor analyses made clear that the requirement extended to pre-existing liens, with a compliance deadline of July 1, 2017. The Board further noted that the filing fee under § 4903.05 and the activation fee under § 4903.06 serve the same fundamental purpose — deterring frivolous liens — citing Angelotti Chiropractic v. Baker (9th Cir. 2015) 791 F.3d 1075 [80 Cal. Comp. Cases 672]. Drawing a distinction between the two fee types to exempt older liens from the declaration requirement would undermine the Legislature's anti-fraud intent. The Board also acknowledged Southland's argument that DWC Newslines had led it to believe its pre-2013 lien was exempt from the declaration requirement. However, relying on Hernandez v. Henkel Loctite Corp. (2018) 83 Cal. Comp. Cases 698, 702 [2018 Cal. Wrk. Comp. LEXIS 23] (Appeals Board en banc), the Board reiterated that DWC Newslines provide only informal guidance and do not carry regulatory authority, which rests with the Appeals Board under Labor Code §§ 5307 and 111. Because no declaration was filed by the July 3, 2017 deadline, the lien was dismissed with prejudice by operation of law, and the Board concluded it retained no jurisdiction over the claim. The petition for reconsideration was denied. Other panel decisions reaching the same conclusion include Carrillo v. Troon Golf Management (January 13, 2025, ADJ4642758) and Cornejo v. Sears Holding Corp. (March 11, 2025, ADJ7580462) [2025 Cal. Wrk. Comp. P.D. LEXIS 65] ...

All workers employed on public works projects in California must be paid the prevailing wage determined by the Director of the Department of Industrial Relations (DIR), CA according to the type of work and location of the project. In essence, prevailing wage is the pay rate that reflects the going compensation for similar work in a given area — these rates are often based on pay rates from local union agreements for similar jobs and are usually higher than the minimum wage. The requirement applies to all employees working on projects when the total cost of the public works project exceeds $1,000. LMCC This is a much lower threshold than the federal requirement of $2,000, meaning more projects in California are subject to prevailing wage laws. There are limited exemptions: if an awarding body has a labor compliance program, prevailing wages are not required for construction projects of $25,000 or less, or for alteration, demolition, repair, or maintenance work of $15,000 or less. Both prime contractors (hired directly by a public agency) and subcontractors must comply with prevailing wage laws. Under California prevailing wage law, workers receive different wage rates for working on legally recognized holidays. All crafts recognize New Year's Day, Memorial Day, July 4th, Thanksgiving Day, and Christmas. Beyond those five universal holidays, not all crafts recognize Veterans Day, Martin Luther King Day, or the day after Thanksgiving — which holidays apply depends on the specific trade classification and its applicable wage determination. As of January 1, 2026, Diwali, known as “Diwali.” (the 15th day of the month of Kartik in the Hindu lunar calendar) was added to Government Code Section 6700 as a holiday. AB 2156 redesignated March 31 from "Cesar Chavez Day" to "Farmworkers Day," and was filed with the Secretary of State on March 26, 2026, taking effect immediately as an urgency statute. Thus the list of holidays specified by Government Code Section 6700 has been changed accordingly. Diwali, often called the "Festival of Lights," is one of the most widely celebrated festivals in Hinduism, Jainism, Sikhism, and some Buddhist traditions. It symbolizes the triumph of light over darkness, good over evil, and knowledge over ignorance. Celebrations typically span five days and include lighting oil lamps (diyas) and candles, fireworks, prayer and worship (particularly of Lakshmi, the goddess of prosperity), feasting, and exchanging gifts with family and friends. It's observed by over a billion people worldwide, making it one of the largest religious celebrations in the world. For crafts whose prevailing wage determination is based on a CBA, these changes may have no immediate impact — those crafts follow whatever holidays are recognized in their specific CBA. The CBA holiday list doesn't automatically update just because Section 6700 changed. For crafts whose prevailing wage determination is not CBA-based, the Section 6700 list is the governing holiday schedule. For those classifications, Diwali and Farmworkers Day (March 31) are now recognized prevailing wage holidays. That means if workers in those non-CBA classifications perform work on those days, they'd be entitled to the applicable holiday pay rate (typically double time, depending on the determination) ...

Former Judge Israel Claustro served on the Orange County Superior Court from 2022 until his resignation on January 12, 2026. His departure from the bench was precipitated by federal criminal charges. On January 7, 2026, the U.S. Department of Justice filed charges against Claustro in U.S. v. Israel Claustro, No. 8:26-cr-00001-FWS (C.D. Cal.), for his role — before he became a judge — in a scheme to defraud the California Subsequent Injuries Benefits Trust Fund. The fraud did not involve his practice of law. Five days later, on January 12, 2026, Claustro pleaded guilty to one felony count of mail fraud and agreed to immediately resign from the bench. He had not yet been sentenced as of the date of the stipulation. According to the plea agreement, Claustro – who was an Orange County prosecutor at the time of the fraud – operated Liberty Medical Group Inc., a Rancho Cucamonga-based medical corporation, despite being neither a physician nor a medical professional as required under California law. One of Liberty’s employees was Dr. Kevin Tien Do, 60, of Pasadena, a physician who had served a one-year federal prison sentence after being convicted in 2003 of felony health care fraud. Because of this conviction, in October 2018, Do was suspended from participating in the California’s workers’ compensation program. Claustro was aware of Do’s prior criminal conviction and suspension from California’s workers’ compensation program. According to the plea agreement, Claustro admitted that he defrauded California’s Subsequent Injuries Benefits Trust Fund (SIBTF), a special fund administered by California’s workers’ compensation program to provide additional compensation to injured workers who already had a disability or impairment at the time of a subsequent injury. Specifically, Claustro paid Do more than $300,000 for preparing medical evaluations, medical record reviews, and med-legal reports after Do’s suspension. Claustro caused Liberty to mail these reports to California’s SIBTF, concealing that they were prepared by Do by listing other doctors’ names on the billing forms and reports. Based on these fraudulent submitted reports, Liberty received hundreds of thousands of dollars from SIBTF. The Commission also found that Claustro had executed his guilty plea agreement on December 8, 2025, yet failed to promptly report the criminal charges to the Commission on Judicial Performance as required by Canon 3D(3) of the Code of Judicial Ethics. Claustro and his counsel, Paul S. Meyer, entered into a Stipulation for Discipline by Consent with Commission Director-Chief Counsel Gregory Dresser under Commission Rule 116.5. Under the stipulation, Claustro admitted that the facts were true, accepted the legal conclusions, and waived any right to further proceedings — including formal proceedings before the Commission and review by the California Supreme Court. The Commission imposed a public censure and bar. Under Article VI, Section 18, subdivision (d) of the California Constitution, the Commission has authority to censure a judge for conduct prejudicial to the administration of justice that brings the judicial office into disrepute. The Commission concluded that Claustro's prebench felony fraud — a crime of moral turpitude — met that standard. Consistent with precedent, commission of a felony alone is a sufficient basis for censure and bar, regardless of the underlying facts of the crime. *See Censure and Bar of Former Judge Ronald C. Kline* (2006) p. 3; Cal. Const., art. VI, § 18, subd. (d); *Broadman v. Commission on Judicial Performance* (1998) 18 Cal.4th 1079, 1111–1112 ...

Glucagon-like peptide-1 receptor agonists (GLP-1 RAs) — including semaglutide (Ozempic, Wegovy), tirzepatide (Mounjaro), liraglutide, and dulaglutide — have become one of the most widely prescribed drug classes in the United States. Originally developed for type 2 diabetes, they now carry FDA approval for obesity and weight-related comorbidities. With over 40% of U.S. adults classified as obese per CDC data, and with obesity being a well-documented risk factor for complications in joint replacement and spine surgery, GLP-1 RAs are increasingly relevant to the injured worker population. More than half of patients undergoing total knee and hip arthroplasty meet criteria for obesity or morbid obesity, making preoperative weight management a frontline concern for orthopedic surgeons treating industrial injuries. Perioperative Risks: Aspiration and Gastric Motility GLP-1 medications slow gastric emptying — a therapeutic feature for appetite control that becomes a serious anesthetic hazard. The American Society of Anesthesiologists (ASA) has issued guidance recommending that patients on **daily-dose** GLP-1 therapy withhold the medication on the day of elective surgery, and patients on **weekly-dose** formulations withhold it for a full week prior. If a patient on GLP-1 therapy presents with gastrointestinal symptoms on the day of surgery, the ASA recommends either postponing surgery or proceeding with "[full stomach precautions](https://journals.lww.com/jbjsjournal/fulltext/2025/08200/glp_1_receptor_agonists_in_orthopaedic_surgery_.17.aspx)." Research presented at the American Academy of Orthopaedic Surgeons (AAOS) 2025 annual meeting in San Diego suggested an even more conservative window — stopping GLP-1s **14 days** before surgery to adequately reduce aspiration risk. Aspiration complications can include bronchial spasms, pneumonia, and death. In the trauma setting, where surgery cannot be delayed, surgeons should use point-of-care gastric ultrasound and full stomach precautions at the surgeon's discretion. Bone Healing and Fusion Concerns This is where the evidence becomes most consequential for workers' compensation claims involving spine and fracture surgery. Spine Surgery: A systematic review and meta-analysis published in the *North American Spine Society Journal (December 2025) pooled data from 13 retrospective cohort studies and found that GLP-1 RA use was associated with a **reduced risk of pseudarthrosis** (failure of bone fusion), with no consistent increase in infection, wound healing complications, cerebrospinal fluid leak, or thromboembolic events. However, the authors cautioned that heterogeneity across studies was notable and causality cannot be inferred. Contradicting these pooled findings, a [study on posterior cervical spine surgery published in *The Spine Journal (September 2025) found that patients on GLP-1 medications had a 4.79 times higher risk of non-union and a 2.12 times higher risk of dysphagia compared to controls. The discrepancy likely reflects differences in surgical approach, patient nutrition status, and GLP-1 exposure timing. Lower Extremity Fractures: A large retrospective cohort study with two-year follow-up found that perioperative GLP-1 RA use was associated with a modestly higher risk of nonunion following lower extremity fracture fixation, though without increased wound complications. Importantly, GLP-1 use was linked to reduced cardiac arrest and one-year mortality — suggesting that the systemic cardiovascular benefits may outweigh the localized bone healing concern for many patients. Joint Replacement: Results are mixed. For total shoulder arthroplasty, patients on GLP-1 RAs showed no increase in length of stay or complications. For total knee arthroplasty, semaglutide was associated with decreased periprosthetic joint infection, sepsis, and readmissions — but also with increased acute kidney injury, pneumonia, myocardial infarction, and hypoglycemic events. Total hip arthroplasty data showed similar infection and readmission benefits without the same medical complication increase. Nutritional and Muscle Mass Implications Rapid weight loss from GLP-1 medications — often 10–15% of body mass over 6 to 12 months — can deplete lean muscle along with fat, particularly in patients over 60 or those not performing resistance training. This sarcopenic effect directly undermines postoperative rehabilitation. Muscle mass and function are essential for ambulation after joint replacement and spine surgery, and insufficient protein intake increases the risk of delayed wound healing and infection. For workers' compensation cases, this creates a practical question: is the injured worker's nutritional status adequate to support surgical healing? Providers should document total weight loss, duration of GLP-1 use, and whether the patient is supplementing with protein or creatine. Practical Takeaways for Workers' Compensation Stakeholders - - Treating physicians and QMEs should document GLP-1 medication use, duration, total weight loss, and nutritional supplementation in every surgical evaluation for an injured worker. - - Utilization review organizations should flag GLP-1 use when evaluating requests for spine fusion, fracture fixation, or joint replacement — and ensure preoperative nutrition optimization is addressed in the treatment plan. - - Claims administrators should be aware that GLP-1-related complications (non-union, revision surgery, aspiration events) may extend claim duration and costs, but that the medications also reduce systemic risks like infection and mortality. - - The standard hold period** before elective surgery remains debated: the ASA recommends 7 days for weekly formulations, while AAOS research suggests 14 days may be safer. Surgeons and anesthesiologists should coordinate on a case-by-case basis ...

IHSS (In-Home Supportive Services) is a California program providing in-home care to eligible aged, blind, or disabled individuals, primarily funded by the state with federal matching. Fraud typically involves providers claiming hours not worked, recipients overstating needs, collusion between providers and recipients, identity theft, or billing for unprovided services. Common charges include grand theft, false claims, and welfare fraud under California Penal Code sections. The California Department of Social Services (CDSS) tracks program integrity through annual reports. Fraud complaints and investigations occur, but criminal prosecutions and convictions represent a small fraction of cases, as many are resolved administratively (e.g., overpayment recovery, service reductions, or terminations). Provider fraud accounts for the vast majority (~80-83%) of investigated cases. Recent news (as of 2026) shows ongoing but limited high-profile IHSS-specific convictions reported publicly; one 2026 LA County DA case involved an IHSS caregiver convicted after surveillance showed physical capabilities contradicting claimed needs. The Special Investigative Unit of RJN Investigations, Inc. was recently notified by the Los Angeles County District Attorney’s Office of their successful prosecution in the case of People of The State of California v M. Lopez based upon a documented fraud referral. In this case, the claimant was employed as a caretaker of the California Department of Social Services – I.H.S.S. At the time of the claimant’s deposition, he appeared wearing a back support and ambulating with the aid of a cane. Proactively, the Senior Claims Examiner authorized the RJN SIU Department to perform RUSH surveillance. During the ongoing surveillance, extensive video evidence was obtained depicting the claimant ambulating freely without any noticeable signs of artificial support or noticeable restrictions. The video evidence was subsequently provided to the QME for review and comment. In his QME report, it stated in part the following: “Overall, review of the subrosa video footage demonstrates a degree of inconsistency between what Mr. Lopez reported and exhibited at the time of the PQME examination, and what he was visualized performing during the video segments…My reporting on this case has changed as a result of this additional information and my revised reporting follows below…” In compliance with the regulations set forth by the California Department of Insurance Fraud Division, the RJN SIU formally filed this case with their office as well as with the Los Angeles County District Attorney’s Office. Felony charges were then issued against the claimant, and a preliminary criminal hearing was set. The claimant failed to appear for the hearing and as a result, a felony bench warrant was issued for his arrest. The claimant subsequently had formal interactions with law enforcement and their check of NCIC revealed his felony warrant where he was promptly arrested. After several criminal hearings, the claimant entered into a plea bargain agreement entailing formal probation and having to pay restitution in the amount of $ 43,263.00 ...

Following alarming reports that California officials failed to properly safeguard federal funds, House Committee on Oversight and Government Reform Committee Chairman James Comer (R-Ky.) and Oversight Committee Republicans launched an investigation into rampant taxpayer fraud in California’s hospice programs. In a letter to California Governor Gavin Newsom, the lawmakers emphasized that the Newsom administration has been aware of state audit reports of hospice fraud for at least four years but has failed to prevent or detect it and has enabled hospice providers to defraud the American taxpayer and exploit vulnerable patients. The Oversight Committee is now requesting documents and communications regarding California’s oversight and internal controls to detect and prevent fraud for its federally funded hospice programs. “Recent reporting has revealed alarming evidence of fraudulent activity in California’s hospice programs, including agencies overbilling Medicare and fraudulently enrolling beneficiaries without their knowledge. In California, your administration’s Departments of Public Health, Social Services and Health Care Services all have a role in overseeing federally funded hospice programs. The Committee is concerned your administration does not have sufficient internal controls to prevent and detect fraud and is not conducting proper oversight of these hospice programs. As a result, Americans across the country are paying for California’s rampant hospice fraud and vulnerable patients are being exploited. California has a well-documented history of fraud in its hospice programs. Your administration has been aware of credible reports of hospice fraud for at least four years. Despite these red flags, it appears California has enabled hospice providers to defraud the American taxpayer and exploit vulnerable patients,” wrote the Republican lawmakers. The Committee’s investigation into Minnesota’s federally funded social service programs exposed widespread failures by state agencies to conduct oversight and prevent fraud, with similar schemes now appearing in California’s hospice programs. According to a March 29, 2022, report from the California State Auditor, Los Angeles County has seen a 1,500 percent increase in hospice providers since 2010, with providers overbilling Medicare by at least $105 million in a single year. In addition, a whistleblower reported that California has minimal safeguards to prevent fraudsters from obtaining hospice licenses, including allowing individuals living abroad to secure them, and described schemes in which fraudsters recruit seniors. The Centers for Medicare and Medicaid Services recently estimated that Los Angeles County alonerepresents $3.5 billion in hospice fraud, and that 18 percent of all hospice billing in the United States comes from this single county. “Last year, California Attorney General Rob Bonta called hospice fraud in California, specifically in Los Angeles County, ‘an epidemic.’ The March 2022 audit report highlighted several red flags and key warning signs of fraud: many providers are listed at the same address; very low patient counts compared with the rest of the State; patients listed as terminally ill were later discharged alive; excessive billing for services that may not have been provided; and staff were shared across multiple hospice providers. The Committee is requesting documents and communications regarding California’s oversight and internal controls to detect and prevent fraud for its federally funded hospice programs,” continued the Republican lawmakers ...