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Dec. 19, 2025

Court of Appeal restores sanity to workers' comp treatment authorizations

A new Second District Court of Appeal decision dismantles the Patterson exception, easing the burden on defendants and restoring common sense to the workers' comp treatment authorization process.

Glenn Olsen

Attorney
Gilson Daub

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Brent Daub

Senior FoundingPartner
Gilson Daub

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Court of Appeal restores sanity to workers' comp treatment authorizations
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The Second District Court of Appeal recently provided some relief and respite from the hornets' nest that is a claims desk. In Illinois Midwest Ins. Agency, LLC v. WCAB/Rodriguez, the Second District of the California Court of Appeal issued a decision that rejected the prior WCAB holding in Patterson v. The Oaks Farm

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