Fernando Cuyugan vs. Bax Global, Inc., American Casualty Co. of Reading, Pennsylvania, Inc.

The Workers' Compensation Appeals Board reversed two orders, one awarding deposition costs and another imposing sanctions against defense counsel. The Board found that the cost award was improper because the applicant did not prevail on their serious and willful misconduct claim, which has a specific cost limitation under Labor Code section 4553. Additionally, the sanctions order was rescinded because the stated grounds of "unreasonable willful delay" did not meet the statutory requirement of "bad-faith actions or tactics" for imposing sanctions. Finally, the Board dismissed the employer's petition for removal concerning the sanctions order as it was a final order subject to reconsideration.