Sedano v. Live Action General Engineering Inc.
The case
John Richard Sedano v. Live Action General Engineering, Inc., et al., ADJ17550375; ADJ17550386. WCAB panel decision 2025 Cal. Wrk. Comp. P.D. LEXIS 193 (reported at 90 Cal.Comp.Cases 1190), with a final sanctions order dated and filed July 29, 2025. Order: https://www.dir.ca.gov/wcab/Panel-Decisions-2025/Richard-SEDANO-ADJ17550375-ADJ17550386.pdf ; Sullivan on Comp's write-up: https://www.sullivanoncomp.com/blog/wcab-warns-against-unchecked-use-of-artificial-intelligence-in-legal-pleadings
What happened
Defense counsel filed a petition for reconsideration riddled with defects: it failed to state the material evidence and cite the evidentiary record (Cal. Code Regs., tit. 8, § 10945(b)), attached 81 pages of documents already in the record (§ 10945(c)(1)), argued permanent-disability apportionment when the trial was solely about temporary disability, and cited cases that were irrelevant, nonexistent, or not citable. Both the presiding WCJ and the WCAB noted the nature, formatting, and syntax of the errors suggested the petition may have been drafted by AI and not reviewed by a licensed attorney. Caveat: the WCAB made no specific finding that AI was used, it expressly held the conduct was sanctionable regardless of how the petition was drafted.
The rule and the sanction
Labor Code § 5813. The WCAB issued a notice of intent to impose up to $2,500; the July 29, 2025 order imposed $750, jointly and severally, on Live Action General Engineering, Inc., National Casualty Company, Gallagher Bassett Services, Inc., Dietz, Gilmor & Chazen, APC, and Maryem Sarwari (CA Bar #244783), payable to the WCAB General Fund. Sedano is cited in Lopez Mendoza (D-55) for the principle that misrepresentations in a verified petition are sanctionable whether or not AI was involved.
How it could have been avoided
The WCAB Rules of Practice and Procedure on reconsideration petitions (Rule 10945) are mechanical and checkable: state the material evidence, cite the record, attach nothing already in it, argue only what was tried. A five-minute form-and-content review against the rule catches every defect in this petition. And verify each cited case exists and is citable before filing, "irrelevant, nonexistent or not citable" authority in a verified petition is sanctionable on its face, AI or not.
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