ADJ15792171 · January 6, 2026

The WCJ found injury AOE/COE to the bilateral elbows in the form of mild lateral epicondylitis based on substantial medical evidence from Dr. Sunny Uppal's reports, which included diagnostic studies. The lien claimant failed to meet the burden of proof for injury AOE/COE to the bilateral wrists, hands, fingers, stress, and psyche.

From the decision · page 1Lien claimant Medland Medical (lien claimant) seeks reconsideration of the Amended Findings of Fact (Amended Findings), issued by the workers' compensation administrative law judge (WCJ) on October 7, 2025, wherein the WCJ found, in pertinent part, that applicant, while employed during the period of May 26, 2021, through January 4, 2022, as a laborer, by defendant, sustained injury arising out of and occurring in the course of employment (AOE/COE) to her right and left elbow in the form of mild epicondylitis, but that lien claimant failed to meet their burden of proof and establish injury AOE/COE to the bilateral wrists, bilateral hands, bilateral fingers, stress, and psyche.

Dr. Sunny Uppal's medical reports diagnosed mild bilateral lateral epicondylitis and ruled out injury to wrists, hands, fingers.

Favours Defendant prevailed

The WCJ found Dr. Uppal's opinion to be substantial medical evidence and relied on it to find compensable injury only to the bilateral elbows.

From the decision · page 6Dr. Uppal M.D. served as the PQME. Dr. Uppal issued two reports. In his initial report dated November 11, 2022, Dr. Uppal noted the applicant's complaints included bilateral wrist pain with numbness, weakness, and tingling that radiated to her hands and fingers. He also noted the applicant had complaints of bilateral hand and finger pain. Dr. Uppal found the applicant had no tenderness, swelling, or deformity in either hand. He also noted the applicant had full range of motions in all digits without any tenderness, swelling, or deformity. Finkelstein and Phalen's tests were negative bilaterally. The applicant also had full range of motion in the bilateral hands and wrists. Dr. Uppal's diagnosis / impressions were the applicant suffered from right and left lateral epicondylitis. He also noted he would like to rule out compressive neuropathy. He requested diagnostic testing, in the form of EMG and nerve conduction study be performed on both upper extremities. (See exhibit 6)

Dr. Omid Haghighinia's report did not diagnose bilateral elbow injury and lacked review of diagnostic studies.

Favours Defendant prevailed

The WCJ rejected Dr. Haghighinia's report as not substantial evidence, weakening the lien claimant's case for compensability of wrists, hands, fingers, stress, and psyche.

From the decision · page 6evaluation and recommendations. Dr. Haghighinia failed to diagnosis right or left lateral epicondylitis. (See exhibit 4)

Evaluated applicant on June 20, 2022, issued a report but failed to diagnose right or left lateral epicondylitis and did not review diagnostic studies.

The WCJ did not find Dr. Haghighinia's report to be substantial evidence as it lacked diagnostic study review and did not diagnose bilateral elbows injury.

From the decision · page 6evaluation and recommendations. Dr. Haghighinia failed to diagnosis right or left lateral epicondylitis. (See exhibit 4)

Diagnosed mild bilateral lateral epicondylitis based on clinical evaluation and diagnostic studies; found no injury to wrists, hands, or fingers; provided future medical care for elbows only.

The WCJ found Dr. Uppal's opinion to be substantial medical evidence and relied upon it to find compensable injury to the bilateral elbows only.

From the decision · page 6Dr. Uppal M.D. served as the PQME. Dr. Uppal issued two reports. In his initial report dated November 11, 2022, Dr. Uppal noted the applicant's complaints included bilateral wrist pain with numbness, weakness, and tingling that radiated to her hands and fingers. He also noted the applicant had complaints of bilateral hand and finger pain. Dr. Uppal found the applicant had no tenderness, swelling, or deformity in either hand. He also noted the applicant had full range of motions in all digits without any tenderness, swelling, or deformity. Finkelstein and Phalen's tests were negative bilaterally. The applicant also had full range of motion in the bilateral hands and wrists. Dr. Uppal's diagnosis / impressions were the applicant suffered from right and left lateral epicondylitis. He also noted he would like to rule out compressive neuropathy. He requested diagnostic testing, in the form of EMG and nerve conduction study be performed on both upper extremities. (See exhibit 6)

Labor Code section 4060

Labor Code section 4060 governs the panel qualified medical evaluator process.

Dr. Uppal served as the PQME and issued reports used to determine injury compensability.

From the decision · page 4While the applicant's claim was delayed, she was referred to Dr. Haghighinia as her primary treating physician. Her attorney also requested a comprehensive medical legal report. (See exhibit 3.) Dr. Haghighinia, evaluated the applicant on June 20, 2022, after her claim had been denied by the defendant and issued a report of the same date. (See exhibit 4.) Subsequently, the parties obtained a panel qualified medical evaluator (PQME) pursuant to Labor Code section 4060. Dr. Uppal M.D. served as the PQME. Dr. Uppal issued two reports dated November 11, 2022, and August 14, 2023. The case proceeded to trial on the morning of August 4, 2025.

Labor Code section 5402(c)

Labor Code section 5402(c) addresses reimbursement for treatment during delay period when medical control is not established.

Lien claimant's claim for reimbursement during delay period was deferred pending injury findings.

From the decision · page 41. Lien claimant is entitled to reimbursement for treatment provided during the delay period for the defendant's failure to establish medical control and provide medical care.

Diagnostic studies (EMG and nerve conduction) reviewed by Dr. Uppal showed essentially normal results, ruling out compressive neuropathy.

From the decision · page 6In his second report dated August 14, 2023, Dr. Uppal reviewed the results from the EMG and nerve construction study and noted the results were essentially normal. Dr. Uppal found the applicant had mild lateral epicondylitis bilaterally as a result of her employment with defendant. Ther was nothing in either of Dr. Uppal's reports to show a diagnosis of injury to the applicant's bilateral wrists, hands, or fingers. He found the applicant had impairment for the bilateral elbows in the form of mild lateral epicondylitis. Dr. Uppal did not provide impairment for the hands, wrist or fingers. Further, Dr. Uppal's provided future medical care for the bilateral elbows. He did not provide future treatment for the wrists, hands, or fingers. (See exhibit 5)