What the panel ordered
The Workers’ Compensation Appeals Board affirmed the Findings and Orders and Award issued by the workers’ compensation arbitrator on April 18, 2024, except that issues related to child support liens were deferred and remanded to a WCJ for further proceedings.p. 3
Petition for reconsideration filed by lien claimant County of Los Angeles Child Support Services Department regarding child support liens; matter remanded for further proceedings before a WCJ.
This docket was decided more than once. Shown here is the latest released decision; we also hold July 8, 2024.
What was disputed, and how it came out
Each issue the panel decided, with the reasoning it gave. An outcome is what this panel did on this record — not a rule, and not a prediction.
The WCAB deferred the issue of child support liens to a WCJ for further proceedings due to jurisdictional and record development issues, affirming the underlying award otherwise.
The facts that decided it
What the panel treated as outcome-determinative, and which side it favoured.
The child support liens were filed in the Electronic Adjudication Management System (EAMS) listing the County as a lien claimant.
Favours Defendant prevailed
This filing triggered the petition for reconsideration and dispute over lien payments.
The parties agreed to remove the child support lien issues from the ADR program and remand them to the WCAB for further proceedings before a WCJ.
Favours neutral
This agreement led to the deferral and remand of the lien issues for further development of the record.
From the decision · page 2Thereafter, on July 8, 2024, we issued an Opinion and Order Granting the Petition for Reconsideration, pending further review of the entire record. Subsequently, the parties voluntarily participated in the mediation program to discuss the issues raised. On September 11, 2026, the parties agreed to and filed a signed “Stipulation to Remand Matter to Trial Level for Further Proceedings.” The Stipulation states: 1. Arbitrator Gilbert Katen issued a decision dated April 18, 2024. At this time, Arbitrator Katen is no longer available. 2. Petitioner County of Los Angeles DCSS filed a timely petition for reconsideration dated May 7, 2024 requesting reconsideration of the statutory child support liens filed as set forth on page 4 of the petition. 3. Based on the petition for reconsideration, at issue are the Findings of fact number 4 and number 6 only as they pertain to County’s liens. 4. There is a dispute as to whether the ADR program has jurisdiction over the child support liens according to the ADR Agreement with SEIU dated 2009.
The rules the panel named
Authorities as the decision cited them, with how this panel applied each one.
Labor Code section 4903
The appeals board may determine and allow as liens against any sum to be paid as compensation any amount determined hereafter as set forth in subdivisions (a) through (i).
Applied to allow child support liens against compensation awards.
From the decision · page 2The ADR Agreement is an attachment to a petition for dismissal to the ADR program, filed on or about August 15, 2016. 5. Parties agree that the record requires further development pursuant to the Appeals Board Opinion dated July 8, 2024. 6. In consideration of the issues above, the parties agree to remove the issue of applicant’s child support liens from the ADR program and to remand that specific issue to the WCAB for further proceedings before the DWC district office. Section 4903 states: The appeals board may determine, and allow as liens against any sum to be paid as compensation, any amount determined hereafter as set forth in subdivisions (a) through (i). (Lab. C. §4903.)
Labor Code section 4903(e)
The reasonable expenses of minor children of the injured employee subsequent to the date of injury shall be allowed in the proportion that the appeals board deems proper.
Applied to child support liens for minor children against compensation awards.
From the decision · page 2Section 4903(e) provides that the reasonable expenses of minor children of the injured employee subsequent to the date of injury “shall be allowed in the proportion that the appeals board deems proper.” (Lab. C. §4903(e).) Here, the liens for child support may be allowed against the awards of compensation, including retroactive temporary disability and permanent disability indemnity. We believe that the Stipulation to remove the child support lien issues from the ADR process and to refer the matter to a WCJ is the most expeditious way to create a complete record relating to the issues raised by petitioner. Thus, we will approve the Stipulation as required by section 5702.
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About this page
- A published decision of the California Workers' Compensation Appeals Board, taken apart by what it turned on. The Board publishes the decision itself; this page adds the extraction and quotes the passage behind every claim.
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