Jessica Garcia worked for The Merchant of Tennis, Inc. (Merchant), a California corporation operating in San Bernardino County, from July through December 2019. In May 2022, she filed a third amended consolidated class action complaint on behalf of herself and other employees, alleging various wage-and-hour violations under the California Labor Code and other federal and state employment laws. While Garcia's motion for class certification was pending in 2024, Merchant pulled approximately 954 current and former employees into mandatory meetings with management and asked them to sign individual settlement agreements releasing their wage and hour claims in exchange for cash payments averaging roughly $918 each — over $875,000 in total. Garcia had not signed an agreement, but the vast majority of putative class members had. In November 2024, Garcia moved to invalidate the settlements, arguing Merchant obtained them through fraud and coercion. The trial court found that Merchant had made "false and misleading" representations to secure the agreements: it gave workers unfounded claims about the low recovery rates in class actions, falsely stated that certain claims had been dismissed, described the releases as limited when they actually covered all claims, marked communications "confidential" to discourage sharing with class counsel, and misleadingly suggested that arbitration agreements barred participation in the lawsuit without disclosing that only 40 percent of workers had such agreements. The court concluded the 954 individual settlement agreements were voidable and ordered a curative notice giving workers 45 days to revoke their agreements and join the class action. The parties then fought over what the curative notice should say about repayment. Merchant wanted the notice to warn workers that if they revoked their settlements and Merchant ultimately prevailed, they could be required to return the money. Garcia argued that including such language would discourage low-wage workers from joining the suit and that any repayment issue could be addressed later through an offset against recovery. The San Bernardino County Superior Court sided with Garcia. Finding no binding California authority on point, the court followed two federal cases — Marino v. CACafe, Inc. (N.D. Cal. Apr. 28, 2017) 2017 WL 1540717 and McClellan v. Midwest Machining, Inc. (6th Cir. 2018) 900 F.3d 297 — and ruled that the curative notice would inform workers they would not be required to return any payment, though the amount received might be treated as an offset against any future recovery. The court rejected Merchant's argument that California's rescission statutes (Civ. Code, §§ 1689, 1691) required immediate repayment, calling that position "simplistic legal analysis" that ignored the complexity of the employer-employee relationship and the court's duty to prevent abuses undermining the administration of justice. The court stayed its order to allow Merchant to seek appellate review. The Court of Appeal granted Merchant's petition for writ of mandate in a 2–1 decision, directing the trial court to vacate its February 28, 2025 order and reconsider the curative notice in the published case of The Merchant of Tennis, Inc. v. Superior Court No. E085766 (March 2026). The majority (Acting Presiding Justice Miller, joined by Justice Codrington) held that California's rescission statutes govern the situation and require the curative notice to inform workers that repayment of settlement funds may be required at the conclusion of litigation. The court acknowledged that under Civil Code section 1693, repayment need not be immediate and can be delayed until judgment without substantial prejudice to the other party. But the majority concluded that neither section 1692 nor section 1693 authorizes a trial court to forgive repayment entirely at the outset of litigation. The court read section 1692 — which permits a court to "in its judgment adjust the equities between the parties" — as contemplating equitable adjustments at the time of final judgment, not at the beginning of a case. The majority found the federal authorities relied on by the trial court unpersuasive, noting that Marino provided no analysis of California rescission law, and McClellan addressed a narrow exception for federal Title VII and Equal Pay Act claims brought by an individual plaintiff, not a California wage-and-hour class action. However, the court stopped short of requiring immediate repayment, holding that the curative notice should inform class members that if they choose to rescind, they could be responsible for repayment at the conclusion of litigation under Civil Code sections 1689, 1691, and 1693, while the trial court retains discretion to adjust equities under section 1692 at the time of judgment. Justice Raphael dissented, arguing that the majority's reading of the rescission statutes was too rigid and that section 1692 grants trial courts broad equitable authority to fashion remedies — including excusing repayment — at any stage of a proceeding, not only at final judgment ...

For decades, Body Mass Index has been the go-to shorthand for obesity in surgical planning. But anyone who has reviewed a lumbar fusion file knows the frustration: BMI treats a 260-pound powerlifter and a 260-pound sedentary claimant as identical risks. As Orthopedics This Week put it, BMI is “about as precise as estimating blood loss by ‘eyeballing the suction canister.’” Now, a new tool is aiming to change that calculus. The Lumbar Subcutaneous Adipose Classification (LSAC) is an MRI-based system that goes beyond simply weighing a patient or calculating a ratio. Rather than producing a single number, the LSAC maps the distribution of subcutaneous fat across the lumbar surgical corridor. According to the OTW report, the system doesn’t just measure fat—it classifies its pattern in a way that turns out to be a powerful predictor of post-operative infections and other complications following lumbar interbody fusion. The LSAC is the latest evolution in a line of research that has steadily chipped away at BMI’s dominance. In 2018, Shaw and colleagues published their Subcutaneous Lumbar Spine (SLS) Index, which measured the ratio of subcutaneous adipose depth to spinous process height at the surgical site using preoperative MRI. Studying 285 patients who underwent laminectomy or lumbar fusion, the team found that the SLS Index was significantly associated with total complications, perioperative complications, and the need for revision surgery—outperforming both BMI and raw fat depth measurements alone. Then came the Spine Adipose Index (SAI), published in The Spine Journal in 2021. A multicenter case-control study of posterior instrumented lumbar fusion patients found that the SAI was more sensitive than either BMI or subcutaneous fat thickness in predicting deep surgical site infections, and it demonstrated excellent inter-observer reliability—meaning different radiologists reading the same MRI would reach the same conclusion. A 2024 study in Global Spine Journal further validated the approach, finding that the Subcutaneous Lumbar Spine Index (SLSI) was a superior predictor of early surgical site infection after transforaminal lumbar interbody fusion across a cohort of over 3,600 patients. The researchers noted that each millimeter increase in subcutaneous fat thickness corresponded to roughly a six percent increase in infection odds—but that accounting for the spinous process height relationship made the prediction even stronger. Where the SLS Index and SAI each produced a single numerical ratio, the LSAC takes the concept further by generating a classification of adipose distribution pattern across the lumbar corridor. Think of the difference between taking a patient’s temperature (one data point) versus mapping the inflammation across an entire joint (a diagnostic picture). The LSAC leverages data already sitting in every preoperative lumbar MRI—no additional imaging, no extra cost—and converts it into an actionable risk category. This matters for the workers’ compensation world because the research base is now clear: site-specific fat distribution is a far better predictor of lumbar surgical complications than BMI. A recent meta-analysis pooling data from seven studies confirmed that localized adiposity measures showed stronger associations with post-operative infection than BMI in spinal fusion procedures. For the Workers' Compensation Industry, this development touches several pressure points. First, preoperative risk stratification: carriers and utilization review teams may soon have a tool that more precisely identifies which claimants face elevated surgical risks—well before the scalpel touches skin. That creates opportunities for prehabilitation protocols, targeted weight-management programs, or frank conversations about risk-benefit tradeoffs that go beyond a generic BMI threshold. Second, causation disputes. When a post-fusion infection develops, the question of whether the infection was a foreseeable surgical complication versus an independent intervening cause is already a common battleground. A preoperative LSAC classification showing high-risk adipose distribution could strengthen the argument that the complication was predictable—and perhaps even that authorization should have required additional safeguards. Third, the “obesity defense” gets more nuanced. Defense counsel have long pointed to BMI as a comorbidity that contributed to poor outcomes. But the LSAC’s ability to differentiate between patients at the same BMI—one with favorable fat distribution, one without—could undercut blanket arguments and demand more granular expert testimony on both sides of the aisle. The LSAC doesn’t replace clinical judgment. No classification system does. But what it does is extract meaningful, reproducible risk information from imaging that is already being ordered in virtually every lumbar fusion case. For an industry that spends billions annually on spinal surgery claims, a better way to identify which patients are heading toward complications—before they get there—is the kind of incremental advance that compounds over thousands of files ...

Kathleen Charles, a dementia patient who was otherwise in good health, was admitted to the memory care wing of WellQuest Elk Grove, a residential care facility in Sacramento County. Her family informed staff that Kathleen was a "wanderer" who needed monitoring, and WellQuest's own service plan noted she required frequent supervision. Three days after admission, Kathleen was found sitting unattended in an outdoor courtyard in direct sunlight on a day when the temperature reached 102 degrees. She had burns covering roughly a quarter of her body and an internal temperature of about 105 degrees. She fell into a coma and died four days later. When Kathleen was admitted, her niece Erika Wright - acting under a durable power of attorney for Kathleen's health care - signed an arbitration agreement on Kathleen's behalf. The agreement provided that "any and all claims or disputes arising from or related to this Agreement or to your rights, obligations, care, or services at WellQuest of Elk Grove shall be resolved by submission to neutral, binding arbitration in accordance with the Federal Arbitration Act." It also contained a delegation clause stating that "an arbitrator will decide any question about whether a claim or dispute must be arbitrated." The agreement designated JAMS as the arbitration administrator but did not reference any specific JAMS rules or provide a link to them. Eight months after Kathleen's death, her family filed suit. On Kathleen's behalf (as survivor claims), plaintiffs alleged elder neglect, negligence, fraud, and a criminal elder abuse tort. Her brother Raymond, niece Erika, and nephew Thomas also brought individual claims for wrongful death and negligent infliction of emotional distress. WellQuest moved to stay proceedings and compel arbitration. The Superior Court Judge denied the motion on multiple grounds. First, the court found that the delegation clause did not "clearly and unmistakably" assign threshold arbitrability questions - including enforceability and unconscionability - to the arbitrator, so the court resolved those issues itself. Second, the court determined that the arbitration agreement was not unconscionable. Third, it held that Raymond, Erika, and Thomas were not parties to the agreement, so their individual wrongful death and emotional distress claims were not arbitrable. Finally, turning to Kathleen's survivor claims, the court exercised its discretion under Code of Civil Procedure section 1281.2, subdivision (c), and declined to compel arbitration, finding that if those claims went to arbitration while the family's individual claims proceeded in court, there was a risk of conflicting rulings on common factual and legal issues. The court also rejected WellQuest's argument that the FAA's procedural provisions governed the agreement, concluding that the phrase "in accordance with the Federal Arbitration Act" did not expressly incorporate the FAA's procedural rules. The Third District affirmed the trial court on all issues in the published case of Wright v. WellQuest Elk Grove -C105070 (March 2026) On the delegation clause, the court held that the language - providing that "an arbitrator will decide any question about whether a claim or dispute must be arbitrated" - fell short of the "clear and unmistakable" standard required to delegate threshold arbitrability issues away from the court. The court contrasted the agreement with the provision upheld in Aanderud v. Superior Court (2017) 13 Cal.App.5th 880, 892, where the clause explicitly covered "the interpretation, validity, or enforceability" of the agreement and incorporated specific JAMS rules that expressly assigned arbitrability to the arbitrator. Here, the clause said nothing about enforceability, unconscionability, or interpretation of the agreement itself, and the JAMS reference included no link to or copy of the applicable rules. Drawing on the reasoning in Ajamian v. CantorCO2e, L.P. (2012) 203 Cal.App.4th 771, 783, the court explained that when delegation language is susceptible to multiple reasonable interpretations — one covering only substantive disputes and the other reaching threshold enforceability questions — the ambiguity cannot satisfy the heightened "clear and unmistakable" standard. On the FAA preemption issue, the court held that the phrase "in accordance with the Federal Arbitration Act" did not expressly designate the FAA's procedural provisions as controlling. Relying on the California Supreme Court's holdings in Cronus Investments, Inc. v. Concierge Services (2005) 35 Cal.4th 376, Cable Connection, Inc v. DIRECTV, Inc. (2008) 44 Cal.4th 1334, and most recently Quach v. California Commerce Club, Inc. (2024) 16 Cal.5th 562, 582, the court reaffirmed that the California Arbitration Act's procedural rules - including section 1281.2, subdivision (c) - apply by default in state court proceedings, and parties must use express language to opt out of them in favor of the FAA's procedural framework. The court acknowledged the contrary result in Rodriguez v. American Technologies, Inc. (2006) 136 Cal.App.4th 1110, where the phrase "pursuant to the FAA" was found sufficient, but disagreed with that reasoning, finding it inconsistent with the principle that a departure from the default CAA framework requires more exacting language. Following Valencia v. Smyth (2010) 185 Cal.App.4th 153, 177, the court concluded the agreement implicitly incorporated the CAA's procedural provisions, leaving the trial court free to apply section 1281.2, subdivision (c), to keep all claims together and avoid conflicting rulings. Because these two holdings disposed of the appeal, the court did not reach the parties' remaining arguments regarding unconscionability or whether Raymond's statutory right to trial preference would independently override arbitration ...

United States Attorney Craig H. Missakian announced criminal charges against an individual for perpetrating a large-scale fraud targeting federal health care funds distributed through the Medicare Advantage program. Anar Rustamov, a national of Azerbaijan who appears to have entered the United States illegally, was indicted by a federal grand jury and charged with health care fraud for a scheme involving thousands of false claims for medical equipment totaling more than $90 million. According to the indictment, Rustamov, 38, formerly of Sunnyvale, California and a national of Azerbaijan, was part of a scheme to submit thousands of fraudulent claims to Medicare Advantage Organizations (“MAOs”) on behalf of unsuspecting beneficiaries for medical equipment such as blood glucose monitors and orthotic braces. The indictment alleges that Rustamov, from October 2024 through June 2025, executed a scheme through an entity Rustamov created, Dublin Helping Hand, to submit large volumes of claims to MAOs offering Medicare Part C benefit plans. The indictment alleges the scheme sought reimbursement of more than $90 million for medical equipment that was not provided, not needed by patients, and not authorized by a medical provider. The listed patients were unaware that Rustamov and others were submitting the claims, and the referring medical provider listed on the submissions did not authorize the claims, according to the indictment. The defendant is at large. Rustamov remains at large (a fugitive). No arrests have been reported, and authorities are seeking him. This appears to be a standalone case based on available public information, with no named co-conspirators or additional arrests announced as of March 23, 2026. Details come primarily from the official DOJ press release and contemporaneous reporting; no public court docket or full indictment text is yet widely available beyond these summaries. United States Attorney Craig H. Missakian added that when “the Administration declared a War on Fraud, it meant to target exactly this kind of conduct. Rustamov participated in a scheme to steal nearly $100 million in taxpayer funds from a program intended to help those who truly need medical care.” The case is being prosecuted by Assistant U.S. Attorney Maya Karwande with the assistance of Lynette Dixon. The prosecution is the result of an investigation by the U.S. Department of Health and Human Services Office of Inspector General and the Federal Bureau of Investigation ...

On April 29, 2024, the EEOC published its Enforcement Guidance on Harassment in the Workplace - the first update to the agency's harassment guidance since 1999. The guidance replaced five prior guidance documents issued between 1987 and 1999 and was approved by a partisan 3-2 vote. The guidance was a sweeping, roughly 90-page document that addressed harassment across every protected characteristic under federal EEO law. The next year, on January 28, 2025, EEOC Acting Chair Andrea Lucas rolled back much of the EEOC's Biden-era guidance related to gender identity discrimination and harassment, aligning with President Trump's Executive Order 14168 signed on Inauguration Day. However, Lucas could not formally rescind guidance that had been previously approved by a majority vote of the Commission, and she was limited to removing certain materials from the EEOC's internal and external websites and other public documents. At that time, the EEOC lacked a quorum, so a formal rescission vote was not possible. Along the way, the State of Texas and the Heritage Foundation sued to enjoin the guidance, arguing it was contrary to law, arbitrary and capricious, and in excess of the EEOC's statutory rulemaking authority. In the case of Texas v. Equal Employment Opportunity Commission, No. 2:24-CV-173 (N.D. Tex. May 15, 2025) a federal district court in Texas agreed, and struck down portions of the 2024 guidance addressing bathroom, dress, and pronoun accommodations, finding the EEOC had exceeded its statutory authority by expanding the definition of "sex" beyond the biological binary. Following up on the announced Andrea Lucas roll back, on January 22, 2026, the EEOC officially voted 2-1 along party lines to formally rescind its 2024 Enforcement Guidance on Harassment in the Workplace in its entirety. Chair Lucas and Commissioner Brittany Panuccio (confirmed in October 2025, restoring the quorum) voted for rescission, while Democratic Commissioner Kalpana Kotagal dissented. It had been anticipated that the EEOC might limit the rescission to portions addressing sexual orientation and transgender status, but the Commission voted to rescind the guidance in its entirety - including sections on race, color, pregnancy, disability, and other protected categories that were largely uncontroversial. Some employment law commentators have theorized that the Trump EEOC chose a complete rescission because it would be easier than making piecemeal edits, and that any replacement guidance might emphasize religious-based harassment and so-called "reverse" harassment. The rescission does not amend Title VII itself or overturn existing Supreme Court precedent, including the Bostock v. Clayton County, Georgia, 590 U.S. 644 (2020) decision holding that Title VII prohibits discrimination based on sexual orientation and gender identity. The guidance was nonbinding and provided stakeholders with information on how the EEOC planned to enforce the law - it did not change employers' underlying legal obligations. Employees can still pursue harassment claims, courts interpret the law independently, and state and local anti-discrimination laws remain unaffected. California's primary anti-discrimination and anti-harassment statute is the Fair Employment and Housing Act (FEHA), codified at Government Code § 12900 et seq. FEHA is one of the most expansive employment civil rights laws in the nation, and it operates entirely independently of the EEOC's guidance. The EEOC's rescission does not alter any California employer's obligations under FEHA. FEHA does not rely on judicial interpretation to extend protections to gender identity and sexual orientation - they are expressly listed in the statute. California law prohibits workplace discrimination and harassment based on gender identity, gender expression, sexual orientation, marital status, sex/gender (including pregnancy, childbirth, breastfeeding and related medical conditions), reproductive health decisionmaking, race (including traits associated with race, such as hair texture and hairstyle), religion (including religious dress and grooming practices), national origin, age, disability, medical condition, genetic information, military or veteran status, and other protected characteristics. The consensus among employment law practitioners is that while the federal enforcement landscape has shifted significantly, employers should not treat the rescission as a green light to relax their anti-harassment programs. The rescission has prompted federal lawmakers to introduce legislation - such as the BE HEARD Act of 2026 - that would amend Title VII to expressly include sexual orientation, gender identity, sex stereotypes, sex characteristics, and pregnancy in the definition of sex. In practical terms, employment lawyers advising California employers are counseling them to maintain their existing anti-harassment policies, training programs, and complaint procedures without any weakening in response to the EEOC's action - because California law independently requires everything the EEOC guidance recommended and more ...

On March 3, 2026, a San Francisco company called RecovryAI announced that the FDA has granted Breakthrough Device Designation to its AI-powered "Virtual Care Assistants" - software designed to guide patients through recovery after joint replacement surgery. The announcement, which coincided with the company's emergence from more than two years of stealth development, signals a potentially significant shift in how post-operative orthopedic care is delivered and documented. The product works like this: after a total knee or hip replacement, the surgeon prescribes the Virtual Care Assistant to the patient. During the first 30 days of recovery at home, the AI checks in with the patient twice daily about sleep, activity levels, diet, pain, and other recovery milestones. It provides guidance drawn from established clinical protocols. When it detects that a patient's recovery is deviating from expected patterns - signs of possible infection, blood clot, wound complications, or functional decline - it escalates to the care team with the relevant clinical context. The FDA's Breakthrough Device Designation is reserved for technologies that address serious conditions and show potential to meaningfully improve existing standards of care. The designation does not mean the product is approved - it means the FDA has agreed to provide the company with earlier and more frequent regulatory engagement as it moves toward authorization. RecovryAI is pursuing clearance under a Class II pathway for patient-facing Software as a Medical Device, and is currently running a multi-site pivotal study at locations including OrthoArizona, one of the nation's largest orthopedic practices, and Mercy Medical Center in Baltimore. If ultimately authorized, the FDA's decision would create an entirely new device classification for patient-facing AI systems in clinical care. The timing is significant. More than 80 percent of surgical procedures in the United States are now performed on an outpatient basis, meaning patients are sent home during the critical early window when most post-surgical complications develop. Joint replacement patients - many of them workers' compensation claimants recovering from workplace injuries - are increasingly navigating that early recovery period without daily clinical oversight. The traditional model of a follow-up visit at two weeks or four weeks leaves a substantial gap that this technology is designed to fill. Why this matters: If this class of technology gains FDA authorization and enters clinical practice, it will generate a continuous, timestamped record of a patient's post-surgical recovery - what the patient reported about their pain, activity, and symptoms, and what guidance they received, twice a day for 30 days. That is a data trail that did not previously exist in most cases ...

Jazmin Ayala-Ventura worked as a janitor for CCS Facility Services–Fresno Inc., a commercial janitorial company, from June 2021 to March 2022. When she was hired, CCS emailed her links to an online onboarding system where she reviewed and electronically signed several company policies, including a five-page "Mutual Agreement to Arbitrate." The system required employees to scroll through each document before they could click "yes" to agree, and offered the option to view the agreement in English or Spanish. The agreement covered "all claims, disputes, and/or controversies … whether or not arising out of Employee's employment or the termination of employment," contained a class action waiver, survived termination of employment, and could only be revoked by a writing signed by both the employee and a CCS human resources representative. CCS agreed to bear all arbitration costs except each party's own legal fees. In August 2024, Ayala-Ventura filed a putative class action against CCS alleging a battery of wage-and-hour violations under the California Labor Code - including unpaid wages, missed meal and rest breaks, failure to reimburse expenses, and unfair business practices under Business and Professions Code section 17200. CCS moved to compel individual arbitration and dismiss the class claims. Ayala-Ventura opposed, arguing the agreement was both procedurally and substantively unconscionable - specifically that its scope was overbroad, it lacked mutuality, and it was indefinite in duration. She relied heavily on Cook v. University of Southern California (2024) 102 Cal.App.5th 312, a Second District opinion that struck down a similar-looking arbitration agreement with USC. The Fresno County Superior Court granted CCS's motion. The court found procedural unconscionability was minimal, distinguished Cook on the facts, and concluded the agreement was not substantively unconscionable. It ordered arbitration of Ayala-Ventura's individual claims, dismissed the class claims, and stayed the case pending arbitration. Because an order compelling arbitration is generally not directly appealable, the Fifth District Court of Appeal treated the appeal as a petition for writ of mandate and denied the petition on the merits in the published case of Ayala-Ventura v. Superior Court --F089695 (March 2024). On procedural unconscionability, the court agreed with the trial court that the degree was minimal. The agreement was adhesive in form, and an employee might reasonably fear losing a job offer by declining it. But the agreement was a clearly labeled standalone document (not a buried clause), was available in two languages, used legible formatting, and there was no evidence of deception or time pressure. On substantive unconscionability, the court addressed each of Ayala-Ventura's arguments. First, on overbreadth, the court acknowledged the agreement's language could be read to reach claims unrelated to employment, but applied Civil Code section 1643 to construe the ambiguity in a way that rendered the agreement lawful - limiting it to employment-related claims. Even under Ayala-Ventura's broader reading, the court found the agreement distinguishable from Cook because CCS is a janitorial services company, not a sprawling university with hospitals and stadiums, making the prospect of wide-ranging non-employment claims far less realistic. Second, on duration, the court found that the agreement's survival clause was not unconscionable in context, again because CCS's limited operations made the concern about perpetual exposure largely speculative. Third, on mutuality, the court found the agreement sufficiently bilateral: unlike the Cook agreement, CCS's version expressly bound the company's related entities and limited claims against employees and agents to acts taken in their capacity as such. Both employer and employee were subject to arbitration on equivalent terms. Finally, the court addressed stare decisis. It clarified that all published Court of Appeal decisions bind all superior courts statewide - the trial court was wrong to suggest Cook was not binding simply because the Fifth District had not yet cited it. However, the court confirmed that trial courts may fairly distinguish binding precedent on the facts, and the Fifth District itself found Cook factually distinguishable for the reasons discussed above ...

Federal Prosecutors announced that a criminal complaint was unsealed charging Karl Czekai, 29, of Carmichael, with making interstate threats against the Judge presiding over his domestic case with his wife. According to court documents, Czekai is separated from his wife, who moved to Oklahoma with their child to get away from him. Once in Oklahoma, Czekai’s wife filed for a protective order against Czekai, alleging that Czekai has held guns up to her and threatened to shoot her multiple times. Also, according to court documents, in February 2026, Czekai began making social media posts about his wife and the Oklahoma judge who granted the protective order and is presiding over related proceedings. These posts include: - - Images of Czekai’s avatar pointing a gun at a sitting judge with “FAMILY COURT” signage on the bench; - - Text threatening the judge that she will no longer be safe: “Hello, judge [VICTIM 1] of the Oklahoma City Courthouse remember me...the comfort of your title, the security of your robe, the certainty of your authority - all of that is about to be tested”; - - Text warning that time is of the essence: “tick tock, Your Honor. You will be the first to set the example. I’m going to diss you publicly. to show future judges, and lawyers I’m not f---ing around”; - - Text advising that he carries a gun: “Updated the gun to something more of what I would carry. I only carry a .45 and I’m definitely a 1911 guy”; and - - Text suggesting he is ready to follow through: “This is the breaking point. This is him saying: enough is enough.” Additionally, and as detailed in court documents, Czekai posted and shared with his wife videos threatening graphic violence against her. If convicted, Czekai faces a maximum statutory penalty of five years in prison. Any sentence, however, would be determined at the discretion of the court after consideration of any applicable statutory factors and the federal Sentencing Guidelines, which take into account a number of variables. The charges are only allegations; the defendant is presumed innocent until and unless proven guilty beyond a reasonable doubt. The Federal Bureau of Investigation is conducting the investigation with assistance from the Midwest City Police Department and the Oklahoma County Sheriff’s Office. Assistant U.S. Attorney Elliot Wong is prosecuting the case ...

Epic Systems Corporation is a major American health information technology company. It develops electronic health records (EHR) software - the systems hospitals and clinics use to store and manage patient medical records. They are the dominant EHR vendor in the United States. Over 1,900 hospitals and 49,000 clinics use Epic's EHR software. Their Care Everywhere interoperability tool exchanges over 20 million patient records daily. On January 13, 2026, Epic Systems Corporation and four healthcare system co-plaintiffs (OCHIN, Reid Health, Trinity Health, and UMass Memorial Health) filed a landmark lawsuit in the Central District of California targeting an alleged syndicate of companies that fraudulently extracted hundreds of thousands of patient medical records from national health data exchange networks - not to treat patients, but to allegedly sell those records to mass tort law firms. The defendants allegedly gained access to the Carequality and TEFCA interoperability frameworks - systems that collectively facilitate over one billion patient record exchanges monthly - by falsely claiming to be healthcare providers retrieving records for treatment purposes. In reality, according to the complaint, the records were being harvested and sold to plaintiff attorneys for use in identifying and recruiting clients for mass tort lawsuits, including PFAS “forever chemical” litigation and other class actions. No law firms are named as defendants - the complaint stops at the companies allegdly selling records to attorneys (LlamaLab, Hoppr, NHPC), not the firms buying them. However, the complaint is unusually detailed about the commercial relationship: LlamaLab advertised at Mass Torts Made Perfect, Hoppr pitched personal injury attorneys directly, and the Integritort predecessor was caught on video demonstrating live record retrieval to a "law firm lead generation business." The complaint is unusually explicit about the role of plaintiff-side attorneys as the downstream buyers of these records. Key details include: - - LlamaLab, Inc. (New York): Described in the complaint as offering “Same-Day Medical Records Retrieval for Law Firms” and “medical-grade AI analysis tools.” LlamaLab sponsored the October 2025 Mass Torts Made Perfect conference, a major national plaintiff attorney gathering, and exhibited in the medical records category. Its CEO, Shere Saidon, presented its services to class action attorneys at that conference. - - Hoppr, LLC (Dallas, TX): Founded by Meredith Manak, also the CEO of defendant Unit 387 LLC. Hoppr’s stated business is to “instantly aggregate all patient records” for law firms and insurance companies. Manak gave a September 2025 presentation to personal injury attorneys titled “How to Request and Receive All of Your Client’s Medical Records In Less Than 48 Hours for 1 Low Flat Fee.” - - PFAS Litigation Targeting: Records returned by RavillaMed to healthcare providers contained no actual treatment information, but instead reorganized existing diagnoses to highlight PFAS (forever chemical) exposure associations — a subject heavily litigated in mass tort court. - - Nationwide Healthcare Provider Corp (NHPC): Defendant Ryan Hilton of the Mammoth entity group is listed as the NPI owner of NHPC, which markets patient record access directly to attorneys. NHPC’s promotional materials boasted it could pull records “straight from providers’ EHRs” to “representative firms” in “minutes, not weeks.” On March 13, 2026, plaintiffs and defendant Critical Care Nurse Consultants LLC d/b/a GuardDog Telehealth entered a Stipulated Judgment and Permanent Injunction, the first resolution in the case. Paragraph 5 of that document reads "GuardDog admits that, since it began operating as a company in 2024, its goal was to provide chronic care management (“CCM”) and remote patient monitoring (“RPM”) for patients, but that did not happen. For the duration of its existence, its business instead focused on requesting, reviewing, and summarizing medical records, and providing those medical records to law firms. GuardDog further admits that its predecessor, Critical Care Nurse Consulting LLC (“CCNC”), provided similar services and medical records to law firms between 2022 and 2024;" This lawsuit represents the first major litigation challenge to what plaintiffs characterize as an organized “Hydra” of entities exploiting health data infrastructure for plaintiff recruitment. Plaintiffs allege that "When caught, rather than stopping their activity, the bad entity owners, operators, and those in their inner circles simply create new companies. The scheme thus operates like a Hydra: when one fraudulent entity is exposed, the bad actors birth a new one. As an example, when concerns were raised to Health Gorilla about one of their connections, an entity called Critical Care Nurse Consulting, over its affiliation with law firms, it abruptly stopped taking patient records via Carequality in September 2024. That very same month, a related organization previously onboarded by Health Gorilla, Defendant SelfRx, began taking large volumes of patient records. Both Critical Care Nurse Consulting and SelfRx are customers of Defendant Unit 387, an intermediary health data broker onboarded by Health Gorilla." The case is ongoing. A scheduling conference is set for April 23, 2026, and several defendants (e.g., the Mammoth group) have filed or are briefing motions to dismiss ...

The Los Angeles Police Department’s Special Operations Division, Major Complaint Unit, arrested Police Officer III Peter Mastrocinque and Police Officer II Nicole Grant after the Los Angeles County District Attorney’s Office filed felony charges related to Unemployment Insurance fraud under California Penal Code Section 550(a)(5) and Insurance Code Section 2101(a). Mastrocinque was appointed to the Department on September 16, 2008, and Grant on October 31, 2016. Both officers are assigned to Newton Division and have been placed on administrative leave as part of this investigation. The investigation, led by the Special Operations Division Major Complaint Unit, responsible for investigating criminal misconduct by Department employees, including fraud, focused on Unemployment Insurance applications submitted by Mastrocinque and Grant during 2020 and 2021. The investigation followed a 2023 review by the Los Angeles County District Attorney’s Office of suspected Unemployment Insurance fraud involving applications submitted during the COVID-19 pandemic. This review raised concerns about applications associated with multiple individuals, including Mastrocinque and Grant, and was subsequently referred to the Los Angeles Police Department’s Special Operations Division for further investigation. Investigators working in partnership with the Los Angeles County District Attorney’s Justice System Integrity Division developed probable cause to believe Mastrocinque and Grant submitted fraudulent Unemployment Insurance applications and received payments to which they were not entitled. Both officers surrendered themselves, were booked, and later released. Nicole Grant was assigned Booking Number 7199424, and Peter Mastrocinque was assigned Booking Number 7199437. The arrests are part of a broader crackdown - in October 2025, the LA County District Attorney's Office charged 13 Los Angeles County employees from seven different agencies with felony grand theft for stealing a combined $437,383 in state unemployment benefits between 2020 and 2023. While working for LA County and receiving paychecks, the 13 defendants allegedly submitted fraudulent unemployment insurance claims to the California Employment Development Department, falsely claiming under penalty of perjury that they earned less than $600 per week. In fact, they earned more than $600 a week, making them ineligible for unemployment benefits. The agencies involved in the 13 cases spanned a wide cross-section of county government, including the Justice, Care and Opportunity Department, the Department of Public Social Services, and others - notably including employees whose very job was to help the public determine whether they were eligible for public benefits. By December 2025 there was a second wave of arrests. Eleven additional LA County employees were subsequently charged with felony grand theft, bringing the total to 24 employees accused of stealing a combined $741,518 in unemployment benefits between 2020 and 2023. Many of these individuals submitted more than 40 fraudulent income certifications - not only omitting their employment in their initial applications, but continuing to submit fraudulent income certifications every two weeks, claiming under penalty of perjury that they were unemployed even as they continued to receive biweekly paychecks from LA County. The arrests of LAPD Officers Mastrocinque and Grant in March 2026 are thus part of this continuing and expanding crackdown, which has now extended beyond general county employees to sworn law enforcement personnel. The cases are being prosecuted through the DA's Justice System Integrity Division, which specifically handles misconduct by public employees. The Los Angeles Police Department’s Special Operations Division Major Complaint Unit investigates unemployment insurance fraud, abuse of benefits, and other allegations of criminal misconduct involving Department personnel. The Unit is committed to aggressively investigating fraud and benefits abuse to ensure accountability, safeguard public resources, and uphold the integrity of the Department ...

Roy Payan and Portia Mason are blind individuals who enrolled as students at Los Angeles City College, a campus of the Los Angeles Community College District (LACCD), in 2015. Both registered with the college’s Office of Special Services and were approved for accommodations - including recorded lectures, preferential seating, access to electronic text materials, and test-taking accommodations - beginning in the Spring 2016 semester. Both students relied on JAWS screen-reading software to access electronic text. Despite their approved accommodations, Payan and Mason encountered pervasive accessibility barriers. Payan received textbook chapters only after they had already been covered in class. Classroom software platforms such as MyMathLab and Etudes were inaccessible, forcing Payan to complete homework through limited tutoring sessions rather than independently like his peers. Library databases, campus computers, and the LACCD and LACC websites were also inaccessible, hampering his ability to register for courses, apply for financial aid, or stay informed about campus life. Both students had difficulty securing test-taking accommodations, and their accommodation letters were provided only in inaccessible print format. Payan was also steered away from a single-semester math course and directed into a slower two-semester sequence because of his disability. The plaintiffs - joined by the National Federation of the Blind and its California chapter - sued LACCD under Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act in March 2017. After the first trial in 2019, the jury awarded $40,000 to Payan and $0 to Mason. All parties appealed, and the Ninth Circuit vacated and remanded in Payan v. Los Angeles Community College District, 11 F.4th 729 (9th Cir. 2021). On retrial, the jury found LACCD liable on fourteen of nineteen factual allegations and determined that LACCD had intentionally violated Title II on nine of them. The jury awarded $218,500 plus attorney’s fees to Payan and $24,000 plus attorney’s fees to Mason. LACCD then moved for remittitur. Relying on the Supreme Court’s decision in Cummings v. Premier Rehab Keller, P.L.L.C., 596 U.S. 212 (2022) - which held that emotional distress damages are not recoverable under Spending Clause antidiscrimination statutes - the district court granted the motion and slashed the awards to $1,650 for Payan and $0 for Mason. The court reasoned that the jury’s verdicts could only be attributed to either emotional distress damages or lost educational opportunities, both of which the court deemed impermissible. The Ninth Circuit reversed and vacated the remittitur, remanding with instructions to reinstate the original jury awards of $218,500 to Payan and $24,000 to Mason in the published case of Payan v. Los Angeles Community College District, No. 24-1809 (9th Cir. Mar. 11, 2026) The panel addressed three issues. First, it found no forfeiture, concluding that LACCD was not barred from challenging emotional distress damages on remand because the issue had not been decided in the prior appeal. Second, the panel agreed with the district court that emotional distress damages are unavailable under Title II of the ADA. Although Title II was enacted under the Fourteenth Amendment and Commerce Clause rather than the Spending Clause, its statutory text defines its remedies as those of the Rehabilitation Act, which in turn incorporates Title VI’s remedial framework. Under Cummings, 596 U.S. at 221–22, and Barnes v. Gorman, 536 U.S. 181, 189–90 (2002), this chain of statutory incorporation means Title II’s remedies are coextensive with those available under contract-law principles - and emotional distress damages are generally not compensable in contract. Third - and critically - the panel held that the district court erred by failing to recognize that the jury’s award could reflect compensatory damages for lost educational opportunities, a form of relief that remains available after Cummings. Agreeing with the Eleventh Circuit’s reasoning in A.W. by & Through J.W. v. Coweta County School District, 110 F.4th 1309, 1315–16 (11th Cir. 2024), the court held that plaintiffs who prove intentional discrimination may recover compensation for the educational benefits they were denied. Because the trial evidence showed that Payan and Mason were effectively barred from meaningful participation in their courses, and because the jury instructions allowed compensation for “any injury” caused by LACCD’s violations, the jury’s award was consistent with the record. The district court abused its discretion by granting remittitur without considering this legally viable basis for the damages. Judge Lee dissented in part. He agreed that emotional distress damages are barred and that lost-opportunity damages remain available in theory, but he concluded that the plaintiffs failed to present sufficient concrete evidence of lost educational opportunities to justify awards exceeding $200,000. In his view, the testimony amounted to generalized descriptions of diminished educational experiences rather than quantifiable economic losses, and the district court’s remittitur should have been affirmed ...

President Donald Trump is set to sign an executive order to formally launch a task force to investigate fraud nationwide, led by Vice President JD Vance. Federal Trade Commission Chairman Andrew Ferguson will serve as vice chair of the Task Force to Eliminate Fraud, while White House aide Stephen Miller will serve as senior adviser. The executive order instructs the task force to develop a comprehensive national strategy against fraud impacting programs administered with state and local governments to provide housing, food, medical, and financial assistance. The order also calls for the development of anti-fraud standards such as proof of identity and other documentation requirements, as well as audits. The order will highlight fraud in Minnesota, among other states. Last year, YouTuber Nick Shirley went viral for filming seemingly vacant daycare centers in Minnesota. The National Desk The Minnesota case has already led to dozens of indictments, including for phony nutrition and autism care programs. Earlier this year, the administration also established a new DOJ division for national fraud enforcement, designed to enforce federal criminal and civil laws against fraud targeting federal government programs, federally funded benefits, businesses, nonprofits, and private citizens nationwide. And locally, Los Angeles County District Attorney Nathan J. Hochman announced the launch of a countywide LA Metro bus advertisement campaign warning everyone that lying or misrepresenting facts to obtain workers’ compensation benefits to which a person is not entitled is a felony. “Knowingly making a false statement to collect workers’ compensation benefits is textbook fraud, and we are filing charges against anyone who engages in it - employees, medical providers, attorneys or any other participants in the schemes,” District Attorney Hochman said. “If you choose to falsify a claim, exaggerate an injury, or create false medical documentation, you are committing a felony, and my office will prosecute you. In fact, the very buses that soon will carry this message are connected to a recent case in which a Metro bus driver is now charged with staging a fake workplace fall to fraudulently obtain benefits.” District Attorney Hochman added: “The goal of workers’ compensation is to protect legitimately injured workers and provide necessary medical care and wage replacement. Fraud diverts resources, increases costs for employers and taxpayers, and undermines public trust in the system.” “Medical professionals play a critical gatekeeping role in the workers’ compensation system,” District Attorney Hochman stated. “Issuing disability notes without proper evaluation or without assessing whether modified duty is appropriate can perpetuate fraud. Knowingly creating or corroborating false documentation is criminal conduct.” Fraud schemes may also involve “capping,” an illegal practice in which attorneys or medical providers pay for client referrals. Kickbacks and referral payments tied to workers’ compensation claims are unlawful and will be prosecuted. Further, it is illegal for businesses to operate without providing workers’ compensation insurance coverage as required by law. While announcing the Office’s campaign, District Attorney Hochman thanked the Healthcare Fraud Division for its work in developing the campaign, particularly Assistant Head Deputy District Attorney Natalie Adomian for her leadership in bringing the initiative to fruition ...

Brothers and tow company owners, Mark Hassan, 46, of Corona Del Mar, and Ahmed Hassan, 35 of Walnut, were arrested on multiple counts of felony insurance fraud after allegedly underreporting employee payroll and paying portions of employees’ wages in cash to defraud workers’ compensation insurance companies out of nearly 6 million dollars of insurance premiums. The California Department of Insurance launched an investigation after receiving two fraud referrals from an insurance company alleging that Mark Hassan, owner of Hadley Tow, underreported his company’s payroll. The Department’s investigation expanded when it received a third fraud referral alleging his brother Ahmed Hassan, owner of California Heights Tow, filed a fraudulent employee injury claim against his insurance policy for a Hadley Tow employee. Mark Hassen, also the owner of FMG Inc., was doing business as Hadley Tow based in Whittier, Courtesy Tow based in Sylmar, Crescenta Valley Tow based in La Crescenta, California Coach Towing based in Walnut, and several other tow companies across the greater Los Angeles area. He also held towing contracts with multiple law enforcement agencies throughout Southern California. During the investigation, detectives learned Mark Hassan used his uninsured tow company, Courtesy Tow, as a “shell company” to conceal portions of Hadley Tow employee payroll to allegedly defraud workers’ compensation carriers of premiums they were owed. Ahmed Hassan, in an attempt to lower his company’s workers’ compensation insurance premiums also underreported employee wages. In addition to hiding and misrepresenting employee wages to their workers’ compensation insurance providers, the Hassan brothers paid portions or all of employee wages without withholding standard deductions, which led to Employment Development Department opening a payroll tax evasion investigation. For both Hadley Tow and California Heights Tow the brothers reported a combined payroll of $3,038,164 to their insurance carriers, but a forensic audit revealed the actual combined payroll for the two companies was $16,716,657. The illegal actions resulted in an estimated premium loss of $5,897,487. Underreporting of workers' compensation insurance in California is illegal and undermines the financial stability of the insurance system, which shifts costs onto other policyholders. It also jeopardizes the availability of benefits for injured workers, hindering their access to necessary support. Unfair competition also arises as fraudulent businesses gain an advantage over ethical ones. Experts at the Department of Insurance are dedicated to protecting consumers by rigorously investigating cases of alleged illegal acts by insurance companies and individuals. Mark Hassan was booked at the Los Angeles County Sheriff - Inmate Reception Center, and Ahmed Hassan was booked at the West Valley Detention Center in Rancho Cucamonga. This case is being prosecuted by the Los Angeles District Attorney’s Office ...

Knee replacement surgery is one of the most common procedures that the workers' compensation industry encounter in serious injury claims. When a warehouse worker blows out a knee, or a construction laborer's joint finally gives way after years of wear, total knee arthroplasty (TKA) often becomes the endgame of treatment. What happens after that surgery - the recovery timeline, the pain management, the return-to-work prognosis — matters enormously in evaluating and resolving these claims. A recent development out of the nation's top-ranked orthopedic hospital may change the way clinicians approach post-surgical knee replacement recovery, with direct implications for workers' compensation practice. In October 2025, researchers at Hospital for Special Surgery (HSS) in New York — ranked number one in orthopedics by U.S. News & World Report for sixteen consecutive years - presented results of a retrospective study on a recovery approach they call the "Quiet Knee" protocol". The findings were shared at the annual meeting of the American Association of Hip and Knee Surgeons (AAHKS). The traditional approach to knee replacement recovery has long emphasized early, aggressive physical therapy - bending, walking, and pushing through pain as quickly as possible. The "no pain, no gain" mentality has been standard guidance for decades. The Quiet Knee protocol challenges that orthodoxy. Instead of aggressive early mobilization, the protocol focuses on controlling inflammation and swelling during the first ten days after surgery through restricted mobility, gentle passive range of motion, and intensive icing (cryotherapy). Structured telerehabilitation replaces the usual push toward immediate in-person physical therapy. The rationale is physiological. According to the HSS researchers, overly aggressive early therapy can trigger a counterproductive cycle: the more a patient bends and walks in the first days after surgery, the more the knee swells, which increases pain, which limits the range of motion the therapy was supposed to restore. The Quiet Knee approach respects the body's inflammatory response and gives the surgical tissue time to begin healing before progressive rehabilitation starts. The HSS study reviewed all of their total knee replacement patients from 2020 through 2024, comparing a cohort of 271 patients who followed the structured Quiet Knee protocol against groups that received either verbal guidance alone or traditional early-motion therapy. Early results suggest that patients following the protocol experienced a smoother recovery trajectory. Notably, the protocol was associated with a reduction in 90-day opioid exposure of more than 25 percent. Why this matters: This protocol is likely to appear with increasing frequency in treatment plans and IME reports involving post-TKA recovery. The study gives institutional support to a conservative, rest-first rehabilitation approach - and the opioid reduction finding adds a significant data point to disputes involving post-operative pain management. Practitioners handling knee injury claims on either side should be aware of it ...

Hector Carreon worked as an order selector at U.S. Foodservice's La Mirada distribution facility. He alleged a pattern of sexual harassment at the warehouse, including a 2018 incident where a coworker tried to grab his genitals and made threatening remarks, and repeated threats from coworker Jesus Torres to sexually assault him in the freezer. Carreon claimed he reported these incidents to managers and his union representative, but was met with indifference or dismissive comments. In July 2019, after being reinstated from an earlier termination through a union grievance, Carreon signed a "last chance agreement" that released US Foods from liability for all prior employment claims. About a month later, on August 29, 2019, Torres physically confronted Carreon in the frozen foods warehouse — pulling him off his pallet jack, throwing him onto shelves, and repeatedly thrusting his groin toward Carreon's face while coworkers watched and filmed. Afterward, Carreon followed Torres around the aisle for several minutes, unplugged his pallet jack, and demanded he delete video that had been posted to Snapchat. US Foods reviewed surveillance footage the next morning, characterized the entire episode as workplace violence, and terminated both Carreon and Torres. Carreon filed a ten-count complaint including sexual harassment, discrimination, retaliation, wrongful termination, and several intentional tort claims. US Foods moved for summary adjudication, and the trial court granted the motion on all claims except sexual harassment and failure to prevent sexual harassment. Those two claims went to a jury trial in September 2022. The jury found for Carreon, awarding $200,000 in emotional distress damages and $1 million in punitive damages. US Foods then moved for judgment notwithstanding the verdict on punitive damages and for a new trial based on alleged instructional error regarding the last chance agreement's release. The court denied the new trial motion but granted JNOV on punitive damages, striking the $1 million award. Carreon sought roughly $1.3 million in attorney fees; the court awarded approximately $350,000. The Court of Appeal affirmed in full in the unpublished case of Carreon v. U.S. Foodservice - B326837 consolidated with B327540, B330590 (March 2026) -upholding the summary adjudication, the jury instructions, the striking of punitive damages, and the attorney fee award. The court held that US Foods carried its burden of showing a legitimate, nondiscriminatory reason for terminating Carreon: violation of its zero-tolerance workplace violence policy. The burden then shifted to Carreon to show pretext, but the court found he offered only his subjective belief that he was not violent, without evidence tying the termination decision to discriminatory or retaliatory motive. The court distinguished cases like *Sandell v. Taylor-Listug, Inc.* (2010) 188 Cal.App.4th 297 and *Kelly v. Stamps.com Inc.* (2005) 135 Cal.App.4th 1088, where plaintiffs presented substantial evidence undermining their employers' stated reasons. On the whistleblower retaliation claim, the court applied the framework from *Lawson v. PPG Architectural Finishes, Inc.* (2022) 12 Cal.5th 703 and found Carreon failed to show his complaints were a contributing factor in his termination. The tort claims were barred by workers' compensation exclusivity because US Foods promptly suspended and fired Torres, negating any ratification theory. The court found no reversible error in instructing the jury that it could consider pre-release conduct when evaluating whether a reasonable person would find the work environment hostile. Citing *Lyle v. Warner Brothers Television Productions* (2006) 38 Cal.4th 264, the court reasoned that prior events provided relevant context for the post-release harassment, and the jury had already found that harassing conduct occurred after the release date before reaching the disputed question. The court affirmed the JNOV, concluding there was no substantial evidence that any US Foods employee involved in the termination decision qualified as a "managing agent" under *White v. Ultramar, Inc.* (1999) 21 Cal.4th 563 and *Roby v. McKesson Corp.* (2009) 47 Cal.4th 686. Even as to those who might qualify, there was no clear and convincing evidence of malice, oppression, or fraud — only, at most, poor judgment. The court found no abuse of discretion. The trial court properly set lead counsel's rate at $750 per hour based on recent comparable awards, then applied a 40% reduction supported by detailed findings about limited success, block billing, duplicative work, and improper billing for clerical tasks. The denial of a fee multiplier was within the court's discretion under *Ketchum v. Moses* (2001) 24 Cal.4th 1122, which does not mandate enhancement even in contingency-fee FEHA cases ...

Medicare Advantage (MA) overpayments are driving up Part B premiums for *all Medicare beneficiaries — including those who remain in Traditional Medicare (TM) and receive none of MA's supplemental benefits. The Joint Economic Committee estimates this cost enrollees an extra $13.4 billion in 2025, with cumulative excess premiums of **$82 billion since 2016**. How the Mechanism Works By law, the standard Part B premium covers roughly 25% of expected Part B spending per aged enrollee. Because MA plans are paid an estimated 120% of what it would cost to cover the same beneficiaries under TM (per the Medicare Payment Advisory Commission), MA overpayments flow directly into higher Part B expenditures — and therefore higher premiums for everyone. The premium does not distinguish between MA and TM enrollees, so TM beneficiaries subsidize the higher MA spending without receiving MA benefits. The math is straightforward: $84 billion in MA overpayments × 60.6% attributable to Part B × 26.4% financed by premiums = **$13.4 billion** in excess premiums, or roughly **$212 per enrollee** in 2025. Who Bears the Burden Approximately 84.9% of the excess premium burden falls on individuals — most commonly as a direct reduction in take-home Social Security benefits, since about 70% of Part B enrollees have premiums withheld from their Social Security checks. Federal taxpayers absorb 9.1% and state taxpayers 6.0%, primarily through Medicaid premium subsidies for low-income enrollees. TM beneficiaries bore roughly $6 billion of the $13.4 billion total in 2025. The geographic impact is uneven: states with low MA enrollment (e.g., Wyoming at 21% MA penetration) see TM beneficiaries paying as much as $770 in excess premiums per MA enrollee in the state, while high-MA states like Minnesota (65% MA penetration) see only $114 — a nearly 7:1 disparity. The Outlook and Policy Implications Per-person Part B expenditures are projected to nearly double by 2035, from approximately $9,100 to over $18,000. All contributing factors — Part B's share of total Medicare spending, the premium financing rate, and MA enrollment — are trending upward. If MA continues to be paid at 120% of TM, the per-beneficiary excess premium burden is projected to grow to roughly $450 per year by 2035. The JEC brief concludes that aligning MA payment levels with TM would directly curb this avoidable premium growth. Gradual reform achieving payment parity could save each senior an estimated $2,600 over the next decade, while protecting net Social Security benefits for 50 million Part B beneficiaries ...

The Division of Workers’ Compensation (DWC) has posted draft regulations regarding Americans with Disabilities Act (ADA) Accommodation to the online forum where members of the public may review and comment on the proposals. The draft regulations include renumbering of prior regulations along with additions and deletions of some language in those sections, and new sections 9004, 9008 and 9009 as follows: A process for requests of blanket offers of accommodation for multiple remote appearances at the Workers’ Compensation Appeals Board (WCAB). New Rule: 9004 Blanket Offers of Accommodation for Remote Appearances in Division of Workers’ Compensation Hearings (a) The Statewide Disability Coordinator can review requests for multiple remote appearances from parties of adjudication cases in division hearings. Disability accommodation requests for remote appearances in DWC hearings should only be made to accommodate disability. There is a separate process under Subchapter 2 of the Workers’ Compensation Appeals Board Rules of Practice and Procedure to request remote appearances for non-disability related reasons like being out of the geographical area. (b) Requests for remote trial appearances should be made with at least 14 days advance notice to the local disability coordinator so that remote appearance(s) can be coordinated. (c) For multiple remote appearance requests on the same day, requests submitted under adjudication pursuant to Rule 10816 as administrative accommodations should not provide an unfair advantage in adjudication. (d) Remote appearances must be effective for all interested parties. Requestors must obtain written approval and provide notice to all interested parties for the remote appearance, including the adjudication officer or workers’ compensation administrative law judge at least 10 days before the appearance. (e) In general, requests for specific remote appearances on blanket offers should be made with as much notice as possible. If the request is made less than five days before the date it is needed for a remote trial appearance, the requestor should be prepared to send another representative to attend the trial in-person. (f) Blanket offers can be revoked by the statewide disability coordinator A new form to file a complaint of disability discrimination. DWC Form 9008 can be used to file a grievance of discrimination on the basis of disability by the division. The Administrative Director will respond in writing to the grievance within 35 days. New Rule 9008: Grievance Procedure DIR DWC Form 9008. This grievance procedure may be used to file a complaint alleging discrimination on the basis of disability in the provision of services, activities, programs, or benefits by the Division of Workers’ Compensation. The complaint should be in writing and contain information about the alleged discrimination such as name, mailing address, phone number, email address of complainant and location, date, and description of the problem. Alternative means of filing complaints, such as personal interviews or a tape recording of the complaint will be made available for a person with disabilities upon request. The complaint should be submitted as soon as possible, preferably within 60 calendar days of the alleged violation to the Statewide Disability Coordinator. The Administrative Director will respond in writing to the grievance within 35 business days of receipt of the grievance. The response will explain the division’s position and offer options for resolution of the complaint. If the response does not resolve the issue, the complainant may appeal the decision within 15 calendar days after receipt of the response to the Administrative Director (AD) or designee. The AD or designee will respond in writing, and, where appropriate, in a format that is accessible to the complainant, with a final resolution of the complaint. Investigations of ineffective accommodations. Litigants that have been affected by courtroom accommodations such as multiple continuances or remote appearances can use the grievance procedure to request an investigation into whether granted accommodations were ineffective. New Rule 9009: Ineffective Accommodations (a) Complaints that granted accommodations were ineffective can be made to the Statewide Disability Coordinator by anyone involved in the accommodation process or affected by requests for accommodation. (b) The Statewide Disability Coordintor will investigate all complaints of ineffective accommodations. The Statewide Disability Coordinator will discuss possible resolutions of the complaint and will determine a final resolution of the complaint. The forum can be found online on the DWC forums web page under “current forums.” Comments will be accepted on the forum until 5 p.m. March 20 ...

The California Department of Insurance, Consumer Watchdog, and State Farm General Insurance Company reached a three-party settlement agreement in the full rate hearing proceeding that is underway to review State Farm’s emergency rate request. The agreement will provide financial relief to many policyholders while ensuring continued coverage for State Farm policyholders while California’s insurance market stabilizes. This settlement agreement, now set to be reviewed by an impartial Administrative Law Judge, follows months of public review and negotiation called for by the Insurance Commissioner under California’s voter-approved Proposition 103 rate hearing process. The settlement reflects the Department’s responsibility to carefully review insurance rates and ensure they are justified, transparent, and fair for California consumers. When he called for the hearing on March 14, 2025, Insurance Commissioner Ricardo Lara stated: “To resolve this matter, I am ordering State Farm to respond to questions in an official hearing, promoting transparency and a path forward.” This proceeding called for by Commissioner Lara required State Farm to provide detailed financial information and testimony regarding its rate request and financial condition, after the Eaton and Palisades fires in Los Angeles, as part of the public review process prescribed under Prop 103. Under California’s rate hearing regulations, the Insurance Commissioner is separated from the negotiation and any details of the evidentiary proceeding while it is underway in order to preserve an impartial and fact-based process. Since that time, the rate hearing proceeding — including at least nine public appearances and advocacy before the Administrative Law Judge regarding multiple discovery motions and disputed evidentiary issues between the parties, as well as status and scheduling conferences, and also including three formal and multiple informal settlement conferences between the parties — has been conducted with participation from experts from the California Department of Insurance and representatives from Consumer Watchdog and State Farm. Under the settlement agreement reached between the California Department of Insurance, State Farm, and Consumer Watchdog, the Commissioner’s prior order granting State Farm’s request for an emergency interim rate increase has been confirmed with the following modifications: - - Homeowners (non-tenant) policies: The interim rate of +17.0% will remain in place, meaning there will be no additional impact to policyholders beyond the currently approved interim rate. - - Rental dwelling policies: The previously approved interim rate of +38% will be reduced to +32.8%, resulting in a rate refund for affected policyholders with 10% interested back to June 1, 2025 . - - Condominium policies: Rates will be reduced from 15.0% to approximately +5.8%, which means policyholders will receive refunds and 10% interest back to June 1, 2025. - - Renters insurance policies: The renters subline will see a slight increase to approximately +15.65% from a currently approved interim rate of 15.0%. - - Refunds with interest: Consumers whose rates were reduced will also receive refunds with 10% interest retroactive to June 1, 2025. In addition, the agreement includes an extension of the current moratorium on homeowners, rental dwelling, condominium, and renters non-renewals and cancellations for at least one additional year, providing continued stability for affected policyholders while the Department continues its broader efforts to stabilize California’s insurance market under its Sustainable Insurance Strategy. Under California’s administrative rate hearing procedures, the parties have now submitted the three-party settlement agreement and supporting documentation to the Administrative Law Judge for review. Settlement Process Timeline - - March 6, 2026: Parties file the settlement agreement with the Administrative Law Judge. - - March 20, 2026: Supporting declarations to be filed with the Administrative Law Judge. - - April 7, 2026 (estimated): Proposed independent decision issued by the Administrative Law Judge if no additional evidence is requested. - - Following the proposed decision, Insurance Commissioner Ricardo Lara will review the proposed decision and make a final decision. - - At a later date, Consumer Watchdog may submit a request for intervenor compensation for its participation in the rate review and settlement process, as authorized under Prop. 103. If approved, the compensation amount – to be paid by State Farm policyholders – will be determined through a separate review process. Learn more about the intervenor compensation process at the Department’s website. Separately, the California Department of Insurance continues its market conduct examination of State Farm General, which is reviewing the company’s claims handling practices and compliance with California law. Results from that examination are expected later this spring ...

A former Orange County resident was sentenced to 84 months in federal prison for threatening to kill a superior court judge who had presided over his family law case. Byrom Zuniga Sanchez, 34, formerly of Laguna Niguel, but whose most recent residence was in Mexico, was sentenced by United States District Judge Fred W. Slaughter to seven years (87 months) in federal prison, exceeding the prosecution's request of six years, citing the grim nature of the threats, Sanchez's lack of contrition, and concerns the threats would continue. He was also ordered to pay approximately $22,798 in restitution. Sanchez was arrested in San Diego in February 2024 after attempting to cross the border into the United States. He represented himself at the three-day trial in December 2025. The jury deliberated for about an hour before convicting him on two counts of threats by interstate and foreign communication. Sanchez has been in federal custody since February 2024. Orange County Superior Court Judge Sandy Leal presided over Sanchez's custody case in 2021. After losing that case, Sanchez moved to Mexico and began targeting the judge.From May 2023 to July 2023, Sanchez sent multiple death threats via email to the victim Judge. Sanchez also threatened to kill or harm others, including other court employees, lawyers, and law enforcement officials. For example, in July 2023, Sanchez emailed the victim Judge’s former courtroom, “I am more committed to murdering you than I am to being present as a father.” In the same email, Sanchez also wrote, “You’re already dead. The remainder of my life will be dedicated to assassinating judges, attorneys, and a police station’s entire shift staff.” Sanchez also sent the judge a music video by rapper Ashnikko, and he posted a threatening video on October 5, 2023. His threats had real consequences: Orange County sheriff's deputies had to set up a command center and increase patrols at the Lamoreaux Justice Center on October 13, 2023, and some court employees stayed home out of fear. Judge Leal, however, testified that she didn't want one person to derail the administration of justice and came to work that day. “[Sanchez’s] terrifying embrace of his offenses – his delight at the pain of others – and his total lack of remorse increases the already substantial need for specific deterrence,” prosecutors argued in a sentencing memorandum. The FBI investigated this matter. Assistant United States Attorneys Alexandra Sloan Kelly of the Transnational Organized Crime Section and Diane B. Roldán of the Major Crimes Section prosecuted this case ...

The term "private credit meltdown" refers to escalating fears of a potential crisis in the private credit market - a sector where non-bank lenders (like investment funds, asset managers, and private equity firms) provide loans directly to companies. This market has ballooned in size and popularity since the 2008 financial crisis, but recent high-profile collapses, rising defaults, and economic pressures have sparked warnings of a broader unwind that could echo the subprime mortgage meltdown. While some experts view it as an imminent threat, others argue the risks are contained and not systemic. The private credit market has grown dramatically: From about $400 billion in 2008 to roughly $2 trillion globally by early 2026. It's projected to reach $4.9 trillion by 2029. A significant portion (around 40%) is concentrated in software and tech firms, which are seen as innovative but volatile. Insurance companies face notable risks from the ongoing turmoil in the private credit market, though the level of jeopardy varies by region, firm, and exposure. Insurers have become major players in private credit, allocating billions to these higher-yield assets to boost returns on policyholder premiums. However, with rising defaults, valuation drops, and AI-driven disruptions in key sectors like software (where ~40% of private credit loans are concentrated), this exposure could lead to significant losses, liquidity strains, or even solvency issues in a worst-case scenario. Critics warn it might spark a broader crisis, echoing 2008's shadow banking woes, but many executives and regulators argue the risks are contained. Post-2008 regulations pushed banks away from risky lending, creating opportunities for non-banks like insurers. North American life insurers now hold about 35% of their portfolios in private credit, up sharply from pre-crisis levels. Globally, insurers manage trillions in these assets, often through partnerships with private equity firms that own or manage insurance arms. For example, firms like Apollo and Blue Owl (which froze redemptions recently) have deep ties to insurance, with policyholder funds funneled into private loans. Based on recent analyses and reports from early 2026, several U.S. life insurance companies, particularly those acquired or heavily influenced by private equity (PE) firms, are flagged as being in potential jeopardy. This stems from their significant allocations to private credit - often through related-party investments - which expose them to risks like credit losses, liquidity strains, interest rate shifts, regulatory tightening, and opacity in asset valuations. These firms represent a subset of the broader industry, where PE ownership has led to higher-risk portfolios to chase yields. Not all insurers are equally affected; traditional players like AXA or Allianz have lower exposures and have publicly downplayed risks. The following list focuses on those specifically highlighted in market discussions and research. - - Athene (owned by Apollo Global Management): Holds 12-18% of assets in related-party investments tied to private credit. Vulnerable to worsening credit cycles, potential spikes in defaults (especially in AI-disrupted sectors like software), and increased capital charges from regulators like the NAIC. Despite strong capital ($34 billion), a downturn could erode buffers and trigger liquidity issues. - - Global Atlantic (owned by KKR): Approximately 22% of assets in related-party private credit investments. At risk of capital shortfalls if private credit assets face stress, such as rising defaults or reduced liquidity amid economic turbulence. The firm's reinsurance strategies and PE ties amplify concerns over transparency and contagion. - - Everlake (formerly Allstate Life Insurance, owned by Blackstone): High exposure with 35% of assets in related-party investments. Jeopardy arises from potential credit losses, interest rate volatility, and stricter regulations, which could force asset sales or capital raises in a stressed market. - - American National Insurance (owned by Brookfield): Around 30% of assets linked to related-party private credit. Risks include opacity in holdings, illiquidity during downturns, and broader market contagion, potentially leading to solvency pressures if defaults rise. These companies are often cited in warnings from investors like Steve Eisman and analysts at firms like Fitch and Moody's, who point to a "slow-brewing scandal" in the life insurance sector due to offshore reinsurance and imbalanced asset-liability structures. However, executives at these firms emphasize managed risks through diversification and stress testing. Broader industry outlooks remain neutral, but a recession or AI-driven disruptions could exacerbate issues. This is not yet a systemic crisis. Default rates remain contained, and the largest private credit platforms emphasize that their portfolios are performing. But the opacity that once shielded private credit from market volatility is now working against it, delaying the recognition of problems and compressing the time available to respond ...