MATT STEEPLE vs. NEW JERSEY RED DOGS, GRANITE STATE INSURANCE/AIG

The Workers' Compensation Appeals Board (WCAB) rescinded the Administrative Law Judge's (ALJ) award, finding the medical evidence insufficient to establish California's jurisdiction over the applicant's cumulative industrial injury. While the applicant sustained injuries as a professional football player, the ALJ's reliance on medical reports based on an incomplete history of California play was deemed not substantial evidence. The case was returned to the trial level for further development of the medical record regarding the connection between the applicant's California work and his injury. The majority noted that jurisdiction over the employer and insurer was established, but the specific issue of liability for the cumulative injury requires further proceedings.