What the panel ordered
Petition for reconsideration filed by Reach Air Medical Services LLC is denied
Petition for reconsideration and removal of Findings and Order of August 24, 2023 in ADJ11927201 filed by lien claimant Reach Air Medical Services LLC
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.
The WCAB found that the Airline Deregulation Act of 1978 does not preempt Labor Code section 4600, relying on the en banc decision in Enriquez and subsequent legal analysis, thus retaining jurisdiction over disputes regarding air ambulance service reimbursement.
The facts that decided it
What the panel treated as outcome-determinative, and which side it favoured.
The WCJ found that Labor Code section 4600 is not preempted by the Airline Deregulation Act of 1978.
Favours Defendant prevailed
This finding established the WCAB's jurisdiction to resolve disputes regarding the value of air ambulance services under state workers' compensation law.