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LA City College Owes Damages for Blind Students Inadequate Accommodations

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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.

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Fraud Crackdowns Announced From Whitehouse to Los Angeles

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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.

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March 9, 2026 – News Podcast

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Rene Thomas Folse, JD, Ph.D. is the host for this edition which reports on the following news stories: WCAB Affirms Take Nothing Based on Worker Credibility Issues. Court Declines to Overturn Arbitration Award in Favor of Employer. Good Forensic Mesothelioma Evidence Leads to $50 M Verdict. LAPD Officer Seen Skydiving Charged with Exaggerating Comp Injury. Multiple Family Members Arraigned for Auto Insurance Fraud. Tragic Death Uncovers Alleged Insurance Fraud. The New CMS TEAM Model May Enhance Workers’ Comp Cases. FSML Annual Employment Law Conference Set for June 5, 2026.

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Owners of SoCal Towing Companies Arrested for $6M Comp Fraud

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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.  

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The Quiet Knee Protocol – Less Is More After Surgery

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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.

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Court Strikes $1M Worker’s Punitive Damages for Lack of Evidence

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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.

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Medicare Advantage Overpayments Inflate Premiums for All

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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.

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DWC posts proposal to update ADA accommodation regulations

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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.

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DOI, Consumer Watchdog and State Farm Reach Settlement

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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.

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Man To Serve 7 Years for Threatening to Kill Orange County Judge

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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.

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