ADJ18095793 · October 12, 2026

The petitions were dismissed as premature because the WCAB concluded that the matter should be returned to the trial level for proper consideration of the petitions as ones to set aside the OACRs, allowing applicant to present evidence and create a record for decision by the WCJ.

From the decision · page 1Applicant, in pro per, essentially seeks to set-aside Orders Approving Compromise and Release (OACRs) issued by the workers’ compensation administrative law judge (WCJs) on September 11, 2024, in various cases. In her Petition for Reconsideration filed in case numbers ADJ18095794, ADJ18095795, ADJ19812111, ADJ19812112, and ADJ19812113, applicant contends that she has no knowledge of case numbers ADJ19812111, ADJ19812112, or ADJ19812113. In her Petition for Reconsideration filed in case numbers ADJ18095793, ADJ18095796, ADJ18120474, ADJ18120475, ADJ18120476, ADJ18201932, ADJ18201962, ADJ19812113, ADJ19812115, ADJ19812116, ADJ19812117, ADJ19812118, ADJ19812119, applicant contends that ADJ18120474 and ADJ18120475 were denied claims, not included in the settlement. Applicant also contends that she has no knowledge of the following case numbers: ADJ19182113, ADJ19182115, ADJ19182116, ADJ19182117, ADJ19182118, ADJ19182119. We received an Answer from defendant. The WCJ issued a Report and Recommendation on Petition for Reconsideration (Report) recommending that the Petition be denied.

Applicant was confused about which cases had been filed and settled on her behalf due to multiple attorneys, WCJs, and overlapping case numbers.

Favours Applicant prevailed

This confusion called into question whether a valid contract was formed for the compromise and release agreements, affecting the validity of the OACRs.

From the decision · page 7the matter for hearing to take evidence when necessary to determine whether the agreement should be approved or disapproved, or issue findings and awards.” (Cal. Code Regs., tit. 8, § 10700(b).) Because the C&Rs were approved at a walkthrough conference, the WCJ did not have the opportunity to assess applicant’s understanding of the proposed settlement agreements. Given the evident confusion that has arisen here, with multiple attorneys and WCJs, and many case numbers, some of which may be duplicate cases, it would not be surprising if applicant did not understand what cases had been filed on her behalf and/or what cases were being settled, which calls into question whether a contract was formed. Moreover, both joint OACRs settled cases that had previously been dismissed (ADJ18201962, ADJ18201932, and ADJ18201916), which calls into question the validity of both OACRs. We note that applicant contends that she has no knowledge of the following case numbers: ADJ19182113, ADJ19182115, ADJ19182116, ADJ19182117, ADJ19182118, ADJ19182119. It appears that “1981” in case numbers ADJ19812113, ADJ19812115, ADJ19812116, ADJ19812117, ADJ19812118, and ADJ19812119 was transposed to “1918” and that applicant is correct.

The joint OACRs settled cases that had previously been dismissed, which calls into question the validity of the OACRs.

Favours Applicant prevailed

Settling dismissed cases undermines the validity of the orders approving the compromise and release agreements.

From the decision · page 7the matter for hearing to take evidence when necessary to determine whether the agreement should be approved or disapproved, or issue findings and awards.” (Cal. Code Regs., tit. 8, § 10700(b).) Because the C&Rs were approved at a walkthrough conference, the WCJ did not have the opportunity to assess applicant’s understanding of the proposed settlement agreements. Given the evident confusion that has arisen here, with multiple attorneys and WCJs, and many case numbers, some of which may be duplicate cases, it would not be surprising if applicant did not understand what cases had been filed on her behalf and/or what cases were being settled, which calls into question whether a contract was formed. Moreover, both joint OACRs settled cases that had previously been dismissed (ADJ18201962, ADJ18201932, and ADJ18201916), which calls into question the validity of both OACRs. We note that applicant contends that she has no knowledge of the following case numbers: ADJ19182113, ADJ19182115, ADJ19182116, ADJ19182117, ADJ19182118, ADJ19182119. It appears that “1981” in case numbers ADJ19812113, ADJ19812115, ADJ19812116, ADJ19812117, ADJ19812118, and ADJ19812119 was transposed to “1918” and that applicant is correct.

Applicant filed Petitions for Reconsideration seeking to set aside the OACRs issued on September 11, 2024.

Favours Applicant prevailed

The petitions initiated the reconsideration process and triggered the Board's review of the validity of the OACRs.

From the decision · page 1Applicant, in pro per, essentially seeks to set-aside Orders Approving Compromise and Release (OACRs) issued by the workers’ compensation administrative law judge (WCJs) on September 11, 2024, in various cases. In her Petition for Reconsideration filed in case numbers ADJ18095794, ADJ18095795, ADJ19812111, ADJ19812112, and ADJ19812113, applicant contends that she has no knowledge of case numbers ADJ19812111, ADJ19812112, or ADJ19812113. In her Petition for Reconsideration filed in case numbers ADJ18095793, ADJ18095796, ADJ18120474, ADJ18120475, ADJ18120476, ADJ18201932, ADJ18201962, ADJ19812113, ADJ19812115, ADJ19812116, ADJ19812117, ADJ19812118, ADJ19812119, applicant contends that ADJ18120474 and ADJ18120475 were denied claims, not included in the settlement. Applicant also contends that she has no knowledge of the following case numbers: ADJ19182113, ADJ19182115, ADJ19182116, ADJ19182117, ADJ19182118, ADJ19182119. We received an Answer from defendant. The WCJ issued a Report and Recommendation on Petition for Reconsideration (Report) recommending that the Petition be denied.

Labor Code section 5909

Petitions for reconsideration must be acted upon within 60 days from the date a trial judge transmits a case to the appeals board, with notice requirements to parties.

The Appeals Board acted timely on the petitions filed by applicant within the 60-day period after transmission and notice.

From the decision · page 4DISCUSSION I. Petitions for reconsideration filed on or after July 14, 2026 are subject to Labor Code section 1 5909, which states that: (a) A petition for reconsideration is deemed to have been denied by the appeals board unless it is acted upon within 60 days from the date a trial judge transmits a case to the appeals board.

Labor Code section 5803

The appeals board has continuing jurisdiction to rescind, alter, or amend any order, decision, or award for good cause upon notice and hearing.

The Board has authority to set aside orders and awards for good cause, which includes mutual mistake, procedural irregularities, and other factors.

From the decision · page 5Thus, we conclude that the parties were provided with the notice of transmission required by section 5909(b)(1) because service of the Report in compliance with section 5909(b)(2) provided them with actual notice as to the commencement of the 60-day period on August 11, 2026. II. Subject to the limitations of section 5804, “[t]he appeals board has continuing jurisdiction over all its orders, decisions, and awards made and entered under the provisions of [Division 4]... At any time, upon notice and after the opportunity to be heard is given to the parties in interest, the appeals board may rescind, alter, or amend any order. decision, or award, good cause appearing therefor.” (Lab.

Cal. Code Regs., tit. 8, § 10700(b)

Compromise and release agreements are contracts requiring mutual consent and meeting of the minds, and the Board must inquire into their adequacy before approval.

The Board noted confusion and possible errors in the settlements and OACRs, warranting further inquiry at the trial level.

From the decision · page 7the matter for hearing to take evidence when necessary to determine whether the agreement should be approved or disapproved, or issue findings and awards.” (Cal. Code Regs., tit. 8, § 10700(b).) Because the C&Rs were approved at a walkthrough conference, the WCJ did not have the opportunity to assess applicant’s understanding of the proposed settlement agreements. Given the evident confusion that has arisen here, with multiple attorneys and WCJs, and many case numbers, some of which may be duplicate cases, it would not be surprising if applicant did not understand what cases had been filed on her behalf and/or what cases were being settled, which calls into question whether a contract was formed. Moreover, both joint OACRs settled cases that had previously been dismissed (ADJ18201962, ADJ18201932, and ADJ18201916), which calls into question the validity of both OACRs. We note that applicant contends that she has no knowledge of the following case numbers: ADJ19182113, ADJ19182115, ADJ19182116, ADJ19182117, ADJ19182118, ADJ19182119. It appears that “1981” in case numbers ADJ19812113, ADJ19812115, ADJ19812116, ADJ19812117, ADJ19812118, and ADJ19812119 was transposed to “1918” and that applicant is correct.

Applicant's confusion regarding multiple case numbers, some dismissed and some settled, and inclusion of dismissed cases in settlements and OACRs.

From the decision · page 7the matter for hearing to take evidence when necessary to determine whether the agreement should be approved or disapproved, or issue findings and awards.” (Cal. Code Regs., tit. 8, § 10700(b).) Because the C&Rs were approved at a walkthrough conference, the WCJ did not have the opportunity to assess applicant’s understanding of the proposed settlement agreements. Given the evident confusion that has arisen here, with multiple attorneys and WCJs, and many case numbers, some of which may be duplicate cases, it would not be surprising if applicant did not understand what cases had been filed on her behalf and/or what cases were being settled, which calls into question whether a contract was formed. Moreover, both joint OACRs settled cases that had previously been dismissed (ADJ18201962, ADJ18201932, and ADJ18201916), which calls into question the validity of both OACRs. We note that applicant contends that she has no knowledge of the following case numbers: ADJ19182113, ADJ19182115, ADJ19182116, ADJ19182117, ADJ19182118, ADJ19182119. It appears that “1981” in case numbers ADJ19812113, ADJ19812115, ADJ19812116, ADJ19812117, ADJ19812118, and ADJ19812119 was transposed to “1918” and that applicant is correct.