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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. ADJ7222283
Regular
Feb 04, 2014

Gregory Montgomery vs. Baltimore Ravens, Tennessee Titans, Travelers Insurance Co.

The Workers' Compensation Appeals Board (WCAB) rescinded a prior award, finding that California's workers' compensation jurisdiction was exempted for the applicant's temporary work in California for the Baltimore Ravens. The WCAB determined that under former Labor Code section 3600.5(b), the Ravens met the requirements for exemption by providing Maryland workers' compensation coverage, which included extraterritorial provisions for employee work in other states. The Board also found that Maryland law reciprocally recognized California's extraterritorial provisions and exempted California employers. Consequently, the applicant's claim against the Baltimore Ravens was dismissed.

Labor Code section 3600.5(b)extraterritorial coveragereciprocityself-insured employerMaryland Workers' Compensation Commissiontemporary employmentprofessional football playercumulative traumaoccupational diseasestatute of limitations
References
0
Case No. ADJ8022272
Regular
Jan 17, 2014

DICK AMBROSE vs. BALTIMORE RAVENS/CLEVELAND BROWNS

This case concerns Dick Ambrose's workers' compensation claim against the Baltimore Ravens/Cleveland Browns. The Administrative Law Judge (ALJ) found that California's workers' compensation jurisdiction was exempt under Labor Code Section 3600.5(b) because the applicant was only temporarily in California and the employer provided coverage under Ohio law. The Appeals Board affirmed the ALJ's decision, largely adopting the ALJ's reasoning regarding the admissibility of evidence and the application of Section 3600.5(b). Commissioner Sweeney dissented, arguing that the applicant's routine work in California over a decade made his presence more than temporary, and also raised concerns about Ohio's reciprocal protections and the employer's self-insurance compliance.

Labor Code Section 3600.5(b)exemption from California jurisdictiontemporary presenceextraterritorial provisionsOhio Revised Codeself-insurancemandatory settlement conferencecumulative injuryprofessional football playeradministrative law judge
References
12
Case No. ADJ14657802
Regular
Sep 19, 2022

STEVE LAUTER vs. BALTIMORE RAVENS FKA CLEVELAND BROWNS, PERMISSIBLY SELF-INSURED, ADMINISTERED BY BERKLEY ENTERTAINMENT, SAN DIEGO CHARGERS, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION FOR FREMONT INSURANCE, IN LIQUIDATION

The Workers' Compensation Appeals Board granted reconsideration of a prior ruling and amended a finding of fact. The Board affirmed that California lacked personal jurisdiction over the Baltimore Ravens (formerly Cleveland Browns) for applicant's claimed injuries. The decision found no evidence of a contract formed in California and that the applicant's activities with the Browns, including games played in California, occurred after his release and were not connected to his claimed injury. The Board also declined to disturb the WCJ's reliance on pre-2005 medical-legal procedures.

Workers' Compensation Appeals BoardPersonal JurisdictionSubject Matter JurisdictionMinimum ContactsSpecial AppearanceContract of HireOffer and AcceptanceOral ContractForum StateLabor Code Section 4062
References
22
Case No. ADJ6836629
Regular
Oct 01, 2013

EVERSON WALLS vs. BALTIMORE RAVENS fka CLEVELAND BROWNS, NEW YORK GIANTS, PMA INSURANCE GROUP c/o GALLAGHER BASSETT and NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PENNSYLVANIA c/o CHARTIS CLAIMS INC., DALLAS COWBOYS, TRAVELERS INSURANCE COMPANY

This case concerns Everson Walls' workers' compensation claim against the Cleveland Browns (now Baltimore Ravens) for an injury sustained while playing professional football. The Board found that Walls was only temporarily employed in California and that the Browns, as a self-insured Ohio employer, provided coverage under Ohio law, which reciprocates California's extraterritorial provisions. Consequently, the Browns are exempted from California workers' compensation law under Labor Code §3600.5(b), and are therefore dismissed from the case.

Workers' Compensation Appeals BoardLabor Code §3600.5(b)National Football LeagueNFLProfessional Football PlayerCumulative Trauma InjuryTemporary Employee ExemptionExtraterritorial CoverageOhio Bureau of Workers' CompensationSelf-Insured Employer
References
9
Case No. ADJ6426842
Regular
Jul 22, 2013

DAN FIKE vs. BALTIMORE RAVENS/CLEVELAND BROWNS

This case concerns a claim for cumulative industrial injury by a professional football player against his former employer. The Workers' Compensation Appeals Board affirmed the administrative law judge's decision that California lacked jurisdiction over the claim. This was based on Labor Code section 3600.5(b), which exempts employees hired outside California and temporarily working within the state, provided the employer has extraterritorial coverage with another state that reciprocally exempts California. The employer, the Browns, successfully demonstrated these conditions were met under Ohio law.

Labor Code section 3600.5extraterritorial provisionsregularly employedtemporarily in Californiahired outside of Californiaself-insured employerOhio workers' compensation lawsCalifornia workers' compensation lawcumulative industrial injuryprofessional football player
References
1
Case No. ADJ7498500
Regular
Jan 29, 2014

JOSEPH DeLAMIELLEURE vs. BALTIMORE RAVENS/CLEVELAND BROWNS, BUFFALO BILLS

This case was remanded to the trial level for reconsideration of the exclusion of evidence concerning the applicability of Labor Code section 3500.5(b). Defendant sought to exempt itself from California workers' compensation coverage for the applicant's temporary employment in the state. The Appeals Board's en banc decision in *Carroll v. Cincinnati Bengals* established precedent regarding this exemption, requiring specific conditions to be met by both the employee and employer. The case is returned for the WCJ to evaluate the evidence and arguments in light of the *Carroll* ruling.

DeLamielleureBaltimore RavensBuffalo BillsLabor Code section 3500.5(b)Carroll v. Cincinnati Bengalsextraterritorial provisionsen banc decisionreconsiderationAmended Findings and AwardWCJ
References
1
Case No. ADJ1360622 (ANA 0407664)
Regular
Jul 22, 2013

LUCIUS SANFORD vs. BALTIMORE RAVENS\/CLEVELAND BROWNS, BUFFALO BILLS

This case concerns an applicant's workers' compensation claim against the Cleveland Browns for injuries sustained as a professional football player. The Appeals Board, reconsidering a prior award, determined that the Browns and the applicant were exempt from California workers' compensation jurisdiction under Labor Code section 3600.5(b). This exemption applies when an employee is hired outside of California, temporarily works within the state, and the employer provides coverage under another state's laws that reciprocally exempts such arrangements. Consequently, the prior award was rescinded, and the Browns were dismissed as a defendant, with the case returned for further proceedings.

WCABADJ1360622Lucius SanfordBaltimore RavensCleveland BrownsBuffalo BillsLabor Code Section 3600.5(b)Findings And AwardWCJpermanent disability
References
1
Case No. ADJ6676904
Regular
May 26, 2010

LOUIS BULLARD vs. CLEVELAND BROWNS, SEATTLE SEAHAWKS, Baltimore Ravens

This case involves a professional athlete claiming workers' compensation injuries from two NFL teams. The Appeals Board granted the defendant's petition for removal after the applicant's death during the pendency of the case. The trial date was vacated, and the matter was returned to the trial level for a priority conference. This is due to the need to address accrued benefits payable to dependents and to potentially identify and join them as parties.

Petition for RemovalWorkers' Compensation Appeals BoardProfessional AthleteMandatory Settlement ConferenceContinued to TrialJoinder as Party-DefendantFurther DiscoveryApplicant's DeathAccrued and Unpaid BenefitsSurviving Dependents
References
1
Case No. ADJ1322108 (ANA 0407206)
Regular
Jul 22, 2013

GLEN YOUNG vs. BALTIMORE RAVENS/CLEVELAND BROWNS, PHILADELPHIA EAGLES, ACE USA

This case concerns the defendant's claim of exemption from California workers' compensation law under Labor Code section 3600.5(b). The Appeals Board found that the applicant, a professional football player hired outside California, was only temporarily working in the state. Based on precedent established in *Carroll v. Cincinnati Bengals*, the Board determined that all conditions for exemption were met, as the employer provided coverage under Ohio law, and Ohio law reciprocally exempts California employers. Consequently, the initial award of permanent disability and future medical treatment was rescinded, and the defendant was dismissed from the case.

Labor Code section 3600.5(b)extraterritorial provisionsprofessional football playercumulative industrial injurypermanent disabilityfuture medical treatmentpetition for reconsiderationen banc decisionCarroll v. Cincinnati BengalsOhio workers' compensation
References
1
Case No. ADJ6718294
Regular
Oct 25, 2011

ANTONIO LANGHAM vs. BALTIMORE RAVENS, CLEVELAND BROWN, SAN FRANCISCO 49ERS, TIG SPECIALTY INSURANCE

This case concerns a professional athlete's workers' compensation claim for multiple injuries sustained between 1994 and 2000. The Workers' Compensation Appeals Board (WCAB) granted reconsideration due to a flawed record, including an incorrect defendant identification and insufficient evidence on jurisdiction and venue. The WCAB rescinded the original decision and returned the case for further proceedings. This will allow for proper identification and joinder of the correct defendant(s) and for the development of a complete record, potentially pending consolidation with other related cases.

Workers' Compensation Appeals BoardProfessional AthleteIndustrial InjuryStatute of LimitationsSubject Matter JurisdictionLabor Code section 3600.5(b)Extraterritorial ProvisionsReconsiderationFindings and AwardPetition for Reconsideration
References
3
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