the blackletter · corpus decision · ← the book
Gaines v. ABM Aviation, Inc. (2026) ADJ20216367 et al.
Appeals Board en banc · binding precedent · 30 pages · retrieved 2026-08-23 · machine-verified 2026-08-23
Open the slip opinion (PDF) · official source (dir.ca.gov)
Holdings & conclusions
“A workers’ compensation settlement is only enforceable after approval by the Workers’ Compensation Appeals Board. In approving a settlement, a WCJ must consider whether the agreement is valid and must determine whether the settlement is adequate in order to protect the injured worker and the public interest.”
“Where the terms of the settlement are inconsistent, do not comply with the Labor Code, and / or are inadequate, the WCJ may investigate by issuing an order suspending action, and if the parties do not provide sufficient information, the WCJ may hold a hearing to create an evidentiary record that establishes the adequacy of a settlement.”
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 (signed as “Paul Kelly” in Gaines)
District office: Van Nuys District Office
Trial judge (named by the corpus): WCJ Karinneh Aslanian (disqualified from further proceedings in all twenty-four consolidated cases by the en banc order)
served: Abramson Labor Group
served: Law Offices of Robert Ozeran
served: Bradford & Barthel
served: Coleman Chavez & Associates
served: Scott Stratman
served: Dabbah, Haddad & Suleiman
served: Acumen
served: Albert and Mackenzie
served: Law Offices of Lydia B. Newcomb
served: Floyd Skeren, Manukian & Langevin
served: Laughlin, Falbo, Levy & Moresi
served: Tobin Lucks
served: Law Offices of Melanie Clayman
served: Law Offices of Natalie Kaplan
served: Brundo Law
served: Employer Defense
served: Helmsman Management
served: Bober, Peterson & Koby
served: Law Offices of Heywood G. Friedman-
served: The Tolwin Group, A Legal Corporation
served: Nicholas Webber
served: Colantoni, Collins, Marren, Phillips & Tulk
served: Hanna, Brophy, Maclean, Mcaleer & Jensen
served: David Jane & Associates
served: Newhouse Creager-
served: Godfrey, Godfrey & Ortega
served: Compwest
Where the book shelves it
§ 1.1 The Weight of En Banc Decisions
§ 1.4 Statutory Construction; Prospective Application of New Interpretations
§ 2.1 Exclusive Jurisdiction of the WCAB
§ 9.6 Replacement of a QME: Jurisdiction, Statutory Rights, and the Good-Cause Factors
§ 14.9 Defendant's Remedies for Frivolous or Bad-Faith Claims
§ 16.3 Pleadings: Informality, Liberal Construction, Amendment to Conform to Proof
§ 16.9 Walk-Through Settlements; Notices of Intention
§ 19.1 No Settlement Without Approval
§ 19.2 Validity: A Settlement Is a Contract
§ 19.3 The Order Suspending Action and the Adequacy Hearing
§ 19.4 What Adequacy Review Protects; What It Does Not
§ 19.5 Information Bearing on Adequacy: Medicals, Civil Actions, Scope
§ 19.6 Stipulations Are Not Held to Substantial-Evidence Proof
§ 20.1 Decisions Rest on the Admitted Record
§ 20.2 Due Process Before the Board
§ 20.3 Electronic Witness Testimony (Rule 10817)
§ 21.2 Reconsideration: The Sixty-Day Period After Transmission (§ 5909)
§ 21.3 Grant of Reconsideration: Effect, Continuing Jurisdiction, and Finality
§ 21.8 Removal
§ 21.9 Consolidation; Vacating an OSA
§ 21.10 Disqualification of the WCJ
§ 24.6 Fraud Reporting; Criminal Proceedings Distinct
§ 26.1 The Reasonable Fee; the Board as Final Arbiter
§ 26.6 Disputed Fees at Settlement Approval
Census accounting
Every sentence of this decision is accounted for: 401 sentences — 114 quoted in the book, the remainder excluded with stated reasons. Ledger: /api/census · quote hashes: /api/verification.