Angelotti Chiropractic v. Christine Baker

OPINION

NGUYEN, Circuit Judge:

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,…