Angelotti Chiropractic v. Christine Baker

In 2012, California enacted Senate Bill 863 (“SB 863”) to combat an acute “lien crisis” in its workers’ compensation system. These liens are filed by medical providers and other vendors to seek payment for services provided to an injured worker with a pending claim. In an effort to clear an enormous and rapidly growing backlog of these liens, SB 863 imposes a $100 “activation fee” on entities like plaintiffs for each workers’ compensation lien filed prior to January 1, 2013. Plaintiffs sued, claiming that SB 863 violates the Takings Clause, the Due Process Clause, and the Equal Protection Clause of the United States Constitution.

We affirm the district court’s dismissal of plaintiffs’ claims under the Takings Clause and Due Process Clause. As to the Equal Protection claim, however, we vacate the preliminary injunction and, through pendent appellate jurisdiction, reverse the district court’s denial of the motion to dismiss this claim.

BACKGROUND

A. Overview of the Workers’ Compensation System

Employers in California typically provide medical care and other services to employees for work-related injuries. See generally Cal. Lab.Code §§ 3600, et seq. An employer or its…