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

Case No. W2023-01693-COA-R3-CV
Regular Panel Decision
Jun 06, 2025

Saint Claude Renal v. Drexel Chemical Company

This appellate case concerns an appeal from the Circuit Court for Shelby County regarding a product liability claim. Plaintiffs, 165 workers from the Dominican Republic, sued Drexel Chemical Company, a Tennessee corporation, under the Tennessee Products Liability Act (TPLA) for alleged injuries caused by toxic herbicides. The trial court dismissed the case, concluding that the TPLA does not have extraterritorial application. On appeal, the Court of Appeals of Tennessee affirmed the trial court's dismissal, holding that the TPLA does not purport to apply extraterritorially, therefore affirming the dismissal of the plaintiffs' action.

Product liabilityExtraterritorial applicationTennessee Products Liability Act (TPLA)Choice of lawPresumption against extraterritorialityToxic herbicidesDominican RepublicShelby CountyCourt of AppealsDismissal affirmed
References
53
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The Workers' Compensation Appeals Board (WCAB) rescinded a prior award, finding that California's workers' compensation jurisdiction was exempted for the applicant's temporary work in California for the Baltimore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. MISSING
Regular Panel Decision

Southwest Travis County Water District v. City of Austin

The Southwest Travis County Water District appealed a trial court judgment that declared its constitutive statute (H.B. 3193) unconstitutional. H.B. 3193 created the District within the City of Austin's extraterritorial jurisdiction, granting it extensive regulatory powers over water, wastewater, drainage, and subdivisions, thereby superseding certain powers of the City. The appellate court affirmed the trial court's decision, concluding that H.B. 3193 was neither a valid general law nor a permissible local law under the Texas Constitution, specifically finding that it failed to comply with general laws requiring the City's consent for the reduction of its extraterritorial jurisdiction.

Constitutional LawLocal GovernmentWater DistrictsSpecial LawsGeneral LawsExtraterritorial JurisdictionHome Rule CitiesTexas ConstitutionStatutory InterpretationPublic Agencies
References
22
Case No. MISSING
Regular Panel Decision

International Ladies' Garment Workers' Union v. Shields & Co.

The case concerns motions by defendants Robert E. Schweser Company and Leonard L. Lawrence to set aside extraterritorial service and dismiss a complaint alleging false representations in the sale of $250,000 in Bridge Revenue Bonds. The plaintiffs, assignees of the Retirement Fund of the Coat and Suit Industry, brought claims under federal securities acts and common law. The court held that extraterritorial service was valid for the federal claims but not for the common law claims, declining to extend pendent jurisdiction to personal jurisdiction. Additionally, the court denied the defendants' motion to dismiss the federal cause of action, confirming the applicability of the Securities Exchange Act to public agency bonds and the assignability of the right of action for misrepresentation.

Securities Act of 1933Securities Exchange Act of 1934Extraterritorial ServicePendent JurisdictionAssignability of ActionFalse RepresentationsBridge Revenue BondsPublic Agency BondsRule 4(f) FRCPRule 54(b) FRCP
References
11
Case No. MISSING
Regular Panel Decision

Travelers Insurance Co. v. Knight

The case concerns an appeal in a Texas Workmen’s Compensation case regarding E. J. Knight, an oil field worker injured in New Mexico while employed by Gene McCutchin. The central issue was whether Knight was covered under the extraterritorial provisions of the Texas Workmen’s Compensation Act, despite his injury occurring out-of-state. The employer, McCutchin, maintained his primary business operations, including payroll and tax reporting, from Dallas County, Texas. The jury found Knight to be a Texas Employee under his original contract of hire, and the appellate court affirmed the trial court's judgment. The court emphasized a liberal construction of the Workmen’s Compensation Statutes and ruled that the place where the contract of hiring took place is not the sole determining factor for extraterritorial coverage.

Extraterritorial CoverageTexas LawNew Mexico InjuryEmployment ContractOil Field WorkerEmployee StatusJurisdictionAppellate ReviewJury VerdictAffirmed Judgment
References
13
Case No. MISSING
Regular Panel Decision
Nov 20, 2012

Securities Investor Protection Corp. v. Bernard L. Madoff Investment Securities LLC

The Trustee (Irving H. Picard) for the Madoff liquidation seeks to recover $42 million from the Taiwanese Bureau of Labor Insurance (BLI), a subsequent transferee of funds originating from BLMIS. BLI moved to dismiss the Trustee’s complaint on four grounds: lack of subject matter jurisdiction under the Foreign Sovereign Immunities Act (FSIA), lack of personal jurisdiction, inability to recover as a subsequent transferee without avoiding initial transfers, and that claims are barred by the presumption against extraterritoriality. The Court denied BLI's motion, finding it has both subject matter and personal jurisdiction over BLI due to BLI's purposeful investment activities in New York-based BLMIS. The Court also ruled that the Trustee can pursue recovery from BLI because the initial transfers are 'avoidable' and the claims are not barred by extraterritoriality, as the statute's focus is on the domestic depletion of the bankruptcy estate.

Bankruptcy LawMadoff Ponzi SchemeForeign Sovereign Immunities ActPersonal JurisdictionSubject Matter JurisdictionAvoidance ActionsSubsequent TransfereeExtraterritorialityCommercial Activity ExceptionFraudulent Transfers
References
72
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. ADJ7225815
Regular
Jun 27, 2012

MICHAEL BARROW vs. WASHINGTON REDSKINS, DALLAS COWBOYS FOOTBALL CLUB, NEW YORK GIANTS, TENNESSEE TITANS, CAROLINA PANTHERS, GREAT DIVIDE INSURANCE administered by BERKLEY SPECIALTY UNDERWRITING MANAGERS, LLC, LEGION INSURANCE in liquidation by CIGA, TRAVELERS

The Workers' Compensation Appeals Board (WCAB) rescinded a prior finding that it had jurisdiction over the Dallas Cowboys for applicant Michael Barrow's injury claim. The WCAB determined that while applicant's agent, a California resident, negotiated the contract and communicated acceptance from Los Angeles, this action alone did not establish a "contract of hire" made in California. Crucially, the applicant himself was not in California at the time of acceptance, and the contract required his personal signature to be fully binding. Therefore, the WCAB lacked jurisdiction over this extraterritorial claim against the Dallas Cowboys.

WCABjurisdictioncontract of hireextraterritorial claimLabor Code 3600.5(a)Labor Code 5305out-of-state injuryprofessional football playeragent authorityoral acceptance
References
13
Case No. ADJ3250254 (ANA 0403409)
Regular
Jul 22, 2013

TROY SADOWSKI vs. CINCINNATI BENGALS

The Workers' Compensation Appeals Board affirmed a WCJ's decision finding no California jurisdiction over a professional football player's claim. The player was hired and covered by Ohio workers' compensation, and his presence in California was temporary for work. This temporary presence, combined with Ohio's reciprocal extraterritorial provisions, exempted the parties from California's workers' compensation law per Labor Code section 3600.5(b). The Board relied on its en banc decision in *Carroll v. Cincinnati Bengals* which established these exemption criteria.

Subject Matter JurisdictionLabor Code Section 3600.5(b)Temporary Presence ExceptionExtraterritorial ProvisionsOhio Workers' Compensation LawCincinnati BengalsProfessional Football PlayerCumulative Industrial InjuryReconsiderationEn Banc Decision
References
3
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
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