ADJ16635028 — California WCAB decision

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.

Penalties under Labor Code §5814Defendant prevailed

The tribunal found that Paperwork & More had notice of the hearing and failed to offer a reasonable excuse for non-appearance; sanctions were appropriate and imposed jointly and severally on Paperwork & More and Stanley B. Johnson, but not on Premier Psychological Services.

From the decision · page 7Whether Sanctions Should be Imposed Against Lien Claimant and/or their Representative [t]he regulations mandate that lien claimants appear at all lien conferences, either in person or by attorney or non-attorney representative.1 The failure to appear at a hearing is sanctionable conduct.2 Sanctions are appropriate for failures to appear where a reasonable excuse is not offered or the offending party has demonstrated a pattern of such conduct.3 (Emphasis added.)

The facts that decided it

What the panel treated as outcome-determinative, and which side it favoured.

Paperwork & More failed to offer a reasonable excuse for failure to attend the December 5, 2024 lien conference.

Favours Defendant prevailed

This failure justified the imposition of sanctions against Paperwork & More and Stanley B. Johnson.

From the decision · page 13FINDINGS OF FACT 1. Paperwork and More, on behalf of Premier Psychological Services, has failed to offer a reasonable excuse for their failure to attend the December 5, 2024 lien conference in accordance with CCR 10421(b)(1).

The rules the panel named

Authorities as the decision cited them, with how this panel applied each one.

Lab. Code, § 4907(b); Lab. Code, § 5813

Non-attorney representatives are held to the same professional standards as attorneys; sanctions may be issued jointly and severally against a legal entity and the natural person responsible.

Sanctions here were issued jointly and severally against Paperwork & More and Stanley B. Johnson, the non-attorney representative.

From the decision · page 13With respect to sanctions, we note that section 5813, subdivision (a) authorizes a WCJ and/or the WCAB to "order a party, the party's attorney, or both, to pay any reasonable expenses, including attorney's fees and costs, incurred by another party as a result of bad-faith actions or tactics that are frivolous or solely intended to cause unnecessary delay." (Lab. Code, § 5813.) Under section 4907(b), non-attorney representatives appearing before the WCAB are held to the same professional standards of conduct as attorneys. (Lab. Code, § 4907(b).) We note that sanctions may be issued jointly and severally against a legal entity, such as a law firm, but orders issued pursuant to section 5813 for a representative's bad faith or frivolous tactics must identify the natural person against whom sanctions are being issued.

Cal. Code Regs., tit. 8, § 10875(a); CCR 10421(b)(1)

Lien claimants must appear at all lien conferences, either in person or by attorney or non-attorney representative; failure to appear is sanctionable conduct.

Sanctions are appropriate for failures to appear where a reasonable excuse is not offered or there is a pattern of conduct.

From the decision · page 7Whether Sanctions Should be Imposed Against Lien Claimant and/or their Representative [t]he regulations mandate that lien claimants appear at all lien conferences, either in person or by attorney or non-attorney representative.1 The failure to appear at a hearing is sanctionable conduct.2 Sanctions are appropriate for failures to appear where a reasonable excuse is not offered or the offending party has demonstrated a pattern of such conduct.3 (Emphasis added.)

Cal. Code Regs., tit. 8, § 10421(b)(1)

From the decision · page 11IV. With respect to the issue of sanctions, WCAB Rule 10421(b)(1) provides the following:

ADJ16635028 · June 26, 2026

What was disputed, and how it came out

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The rules the panel named

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