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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The Workers' Compensation Appeals Board (WCAB) rescinded a prior award, finding that California's workers' compensation jurisdiction was exempted for the applicant's temporary work in California for the Baltimore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
Case No. ADJ8059593
Regular
May 30, 2017

BRIAN VON DURING vs. COUNTY OF LOS ANGELES

The Workers' Compensation Appeals Board denied the County of Los Angeles' petition for reconsideration. The County argued the applicant, injured while participating in a work release program, was not an employee and was exempt from workers' compensation. The Board adopted the Judge's report, upholding the original Findings and Award granting benefits. The applicant's eligibility as an employee under the work release program was implicitly confirmed.

Work release programinmate exemptionwork release applicantself-insured employerWCJ report adoptionPetition for Reconsideration denialFindings and Awardworkers' compensation eligibilityemployee statusCounty Jail exemption
References
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
Case No. ADJ2295331 (ANA 0397551)
En Banc
Jun 18, 2013

Wesley Carroll vs. Cincinnati Bengals, New Orleans Saints, Louisiana Workers' Compensation Corporation, Travelers Insurance

The Appeals Board held that under Labor Code § 3600.5(b), an employee hired outside California is exempt from the state's workers' compensation laws if they are temporarily in the state for work, the employer provides coverage from another state, and that state has reciprocal exemption provisions, leading to the dismissal of the Cincinnati Bengals from the case.

WCABEn BancReconsiderationLabor Code § 3600.5(b)ExemptionExtraterritorial ProvisionsOhio Workers' CompensationSelf-Insured EmployerTemporary EmploymentCumulative Injury
References
Case No. ADJ2295331 (ANA 0397551)
Significant
Jun 18, 2013

Wesley Carroll vs. Cincinnati Bengals, New Orleans Saints, Louisiana Workers' Compensation Corporation, Travelers Insurance

The Appeals Board held that an out-of-state employee and employer are exempt from California's workers' compensation system under Labor Code section 3600.5(b) when the employee is only temporarily in California, the employer provides coverage under another state's similar laws, and that state offers reciprocal exemption to California employers. Consequently, the Cincinnati Bengals were dismissed as a defendant.

Workers' Compensation Appeals BoardEn Banc DecisionLabor Code § 3600.5(b)Extraterritorial CoverageTemporary EmploymentSelf-Insured EmployerOhio Workers' Compensation LawReciprocityCumulative InjuryHire Outside of California
References
Case No. ADJ8552668
Regular
Oct 12, 2015

ANTONIO TRUJILLO vs. PAMA MANAGEMENT COMPANY / NIJJAR REALTY, PACIFIC COMPENSATION INSURANCE COMPANY, CNA

The Workers' Compensation Appeals Board granted reconsideration of a prior decision that denied Western Imaging Services, Inc.'s (WIS) lien claim for photocopying services. The Board found that the administrative law judge improperly excluded exhibits offered by WIS, which would have established its exemption from licensing requirements as an independent contractor of an attorney. The case is returned for further proceedings to determine WIS's exemption and the reasonableness of its fees.

Workers' Compensation Appeals BoardLien ClaimantPetition for ReconsiderationBusiness and Professions CodeProfessional PhotocopierExemptionsIndependent ContractorState BarAdmissibility of EvidenceSanctions
References
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
Case No. ADJ9113575
Regular
Jul 26, 2018

DOUGLAS FAVELL vs. COLORADO ROCKIES/NEW JERSEY DEVILS, TORONTO MAPLE LEAFS, PHILADELPHIA FLYERS, OKLAHOMA CITY BLAZERS, SAN FRANCISCO SEALS, PINNACOL ASSURANCE

This case involved a professional hockey player's workers' compensation claim for injuries sustained across multiple teams from 1965-1979. The Workers' Compensation Appeals Board denied the Toronto Maple Leafs' petition for reconsideration. The Board affirmed the finding that the Colorado Rockies, and their insurer Pinnacol Assurance, were exempt from California workers' compensation laws under Labor Code section 3600.5(b) due to reciprocal exemptions with Colorado law at the time of employment. Consequently, Toronto was held liable as the next employer over which California had jurisdiction.

Workers' Compensation Appeals BoardIndustrial InjuryProfessional Hockey PlayerPermanent DisabilityFuture Medical TreatmentLabor Code Section 3600.5(b)Labor Code Section 5500.5(a)ExemptedReciprocal StatuteColorado Revised Statute
References
Case No. ADJ8387626
Regular
Oct 29, 2015

ANA DIAZ vs. SAMBRAILO PACKAGING, INC., ZENITH INSURANCE COMPANY

This case involves a lien claim for photocopying services provided by California Imaging Solutions (CIS). The WCJ initially disallowed the lien because CIS was not registered as a professional photocopier, as required by Business and Professions Code section 22450. However, the Appeals Board granted reconsideration, finding that CIS was exempt from this registration requirement under Business and Professions Code section 22451(b) because it acted as an agent or independent contractor for applicant's attorney. The case is returned to the trial level to address record deficiencies and re-evaluate the lien claim's compensability in light of this exemption.

Lien ClaimantReconsiderationFindings And OrderAdministrative Law JudgeWCJProfessional PhotocopierBusiness and Professions Code Section 22450Business and Professions Code Section 22451(b)State BarAgent
References
Case No. ADJ7483398 MF ADJ7117818 ADJ7117817
Regular
Sep 24, 2014

CARLOS CACIQUE vs. METRO PAD & FUSING, OAK RIVER INSURANCE, SOUTHERN INSURANCE COMPANY

This case concerns a lien claim by California Imaging Solutions (CIS) for document copying services provided to the applicant's attorney. The original decision disallowed the lien, finding CIS was subject to professional photocopier registration requirements and lacked proof of compliance. CIS argued exemption under Business & Professions Code section 22451(b) as an agent or independent contractor of the attorney. The Appeals Board rescinded the original decision and returned the case for further development of the record to determine if CIS qualifies for the exemption. The stipulated reasonable value of CIS's services is $1,000.

Workers' Compensation Appeals BoardLien ClaimantProfessional PhotocopierBusiness and Professions Code Section 22450Business and Professions Code Section 22451(b)Registration RequirementsExemptionAgentIndependent ContractorHinden & Breslavsky
References
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