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Siegel, Moreno & Stettler Secures Take-Nothing Decision on $37k Chiropractic Lien

Siegel, Moreno & Stettler Secures Take-Nothing Decision on $37k Chiropractic Lien

Dany Oliva v. Lamppost Pizza; Employers Insurance Group, ADJ21361466

On September 8, 2026, Siegel, Moreno & Stettler, through attorney Julia Hielbron, secured a take-nothing decision against the $36,929.40 lien asserted by First Choice Higashi Chiropractic Clinic Inc. The lien claimant did not file a petition for reconsideration by the statutory deadline, and the decision became final on October 5, 2026.

Case Background

The lien arose from self-procured primary treating physician services, including chiropractic treatment, acupuncture, and shockwave therapy, provided both before and after the underlying claim was denied. Injury arising out of and occurring in the course of employment, commonly referred to as AOE/COE, remained disputed.

The defense raised AOE/COE and licensing issues, including whether the individual acupuncturist possessed the required site-specific wall license. The defense trial brief focused on the provider’s compliance with the statutory and regulatory requirements governing chiropractic and professional corporations.

Licensing Defect Bars the Lien

The threshold issue was whether the lien was barred because the provider failed to comply with applicable business and professional licensing requirements.

Anaheim Workers’ Compensation Judge Josephine Broussard concluded that the lien was barred as a matter of law because First Choice Higashi Chiropractic Clinic Inc. provided treatment without first obtaining a Certificate of Registration from the California Board of Chiropractic Examiners.

The lien claimant presented several documents in response, including corporate registration records filed with the California Secretary of State, a fictitious business name statement, individual chiropractic and acupuncture licenses, and a city business license. Those documents, however, did not establish that the corporation had satisfied the separate registration requirements of the applicable professional licensing board.

The decision reinforces that strict compliance with professional licensing requirements is a prerequisite to payment. The same licensing defect could therefore bar recovery even if the underlying workers’ compensation claim had been accepted.

Additional Acupuncture Licensing Issue

The WCJ also found that the acupuncturist lacked the required wall license at the facility where services were performed. That defect independently barred the acupuncture charges. However, because the corporation’s registration failure barred all charges, the additional acupuncture licensing issue did not change the ultimate result.

Broader Significance

This decision provides defendants with a strong basis to challenge other liens asserted by First Choice Higashi Chiropractic Clinic Inc.. Siegel, Moreno & Stettler intends to assert the decision’s preclusive effect, including res judicata where applicable, in opposition to the lien claimant’s efforts to proceed with other liens or future lien trials.

The result also offers a broader reminder to defendants and claims administrators: corporate and professional licensing compliance should be evaluated early when investigating and defending medical-provider liens. A provider’s possession of an ordinary business license or individual professional licenses does not necessarily establish that the provider entity itself is properly registered and legally entitled to payment.

Siegel, Moreno & Stettler is here to help. Contact us to learn more.

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