Zenith Wins Against 'Unlicensed' Surgery Center

In an opinion not certified for publication, the Fourth District of the California Court of Appeals ruled that a lien claimant bears the burden of proving license and accreditation to establish its right to reimbursement. In Zenith Ins. Co. v. WCAB, No. D046783, 03/20/2006, Gilberto Capi injured his back while working for International Coil Bindery and received treatment from various providers, including Beach Cities Surgery Center (Beach Cities) and Pain Intervention Therapy of San Diego (PIT; together the lien claimants). Capi's health care providers sought reimbursement and facility f...