the blackletter · corpus decision · ← the book
DiFusco v. Hands On Spa (2025) ADJ7445107
Appeals Board en banc · binding precedent · 17 pages · retrieved 2026-08-23 · machine-verified 2026-08-23
Open the slip opinion (PDF) · official source (dir.ca.gov)
Holdings & conclusions
“All en banc decisions are binding on panels of the Appeals Board and WCJs, and the binding en banc decisions in Coldiron I and Coldiron II require disclosure of any entities liable for payment and any insurance policies that impact liability for payment.”
“Only the Appeals Board is statutorily authorized to issue regulations for adjudication for workers’ compensation proceedings, and WCAB Rules 10390, 10400 and 10401 require that parties, their representatives, and their insurance companies be fully identified.”
“WCAB Rule 10390 does not supersede the Coldiron decisions. Defendants must comply with WCAB Rule 10390 and the disclosure requirements in Coldiron I and II, regardless of whether there is a third-party administrator.”
The tribunal
Chair: Katherine A. Zalewski
Commissioner: José H. Razo
Commissioner: Katherine Williams Dodd
Commissioner: Craig L. Snellings
Commissioner: Joseph V. Capurro
Commissioner: Paul F. Kelly
District office: Van Nuys District Office
Former commissioner (noted): Commissioner Sweeney (noted in fn. 1 as no longer a member of the Appeals Board; on the panel that granted reconsideration)
served: Asvar Law, PC
served: Michael Sullivan & Associates LLP
Where the book shelves it
§ 1.1 The Weight of En Banc Decisions
§ 1.2 En Banc Precedent: Stare Decisis; No Supersession by Regulation
§ 1.3 The Appeals Board as Court; Rulemaking Authority and Its Limits
§ 16.2 Identification of Parties and Liable Entities; the Coldiron Disclosures
§ 17.1 Discovery: Liberal Policy; No Good-Cause Showing for Routine Requests
§ 22.1 Disclosure of Insurance Policies and Provisions Affecting Liability
Census accounting
Every sentence of this decision is accounted for: 239 sentences — 81 quoted in the book, the remainder excluded with stated reasons. Ledger: /api/census · quote hashes: /api/verification.