LEONEL ENCISO SANTOS vs. RCR PLUMBING MECHANICAL, ARCH INSURANCE SERVICES, GALLAGHER BASSETT SERVICES, INC.

This case involves petitions to dismiss liens based on untimely declarations required by Labor Code section 4903.8(d). The Appeals Board affirmed the trial judge's denial of dismissal, finding the statute does not mandate dismissal for pre-2013 liens filed untimely. However, the Board amended the findings to formally admit Foundation's corrected declaration and remanded for the WCJ to consider sanctions against the lien claimants for their delays.