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

Case No. ADJ9086089
Regular
Jul 14, 2015

**ADAM TIMMERMAN,** vs. **ST. LOUIS RAMS, LLC; GREAT DIVIDE INSURANCE COMPANY; TRAVELERS INDEMNITY COMPANY,**

The Workers' Compensation Appeals Board (WCAB) denied Adam Timmerman's claim for workers' compensation benefits against the St. Louis Rams and their insurers. The WCAB found that Timmerman's participation in 14 games in California, out of 189 total games in his career, did not establish a sufficient connection to California to justify the application of California workers' compensation law. This decision followed the precedent set in *Federal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)*, which requires a legitimate and substantial connection between the injury and the state for jurisdiction. The majority affirmed the WCJ's findings, concluding that California lacked a substantial interest in adjudicating this claim.

Workers' Compensation Appeals BoardSt. Louis RamsTravelers Indemnity CompanyWCAB jurisdictionProfessional athlete injuryCumulative industrial injuryCalifornia workers' compensation lawFederal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)Legitimate and substantial connectionDe minimis
References
10
Case No. ADJ7286848
Regular
Aug 03, 2015

EMANUAL DAVIS vs. ATLANTA HAWKS, FEDERAL INSURANCE (CHUBB GROUP OF INSURANCE COMPANIES), TIG INSURANCE COMPANY, HOUSTON ROCKETS, SEATTLE SUPERSONICS, LIBERTY MUTUAL INSURANCE COMPANY

This case concerns a professional basketball player's cumulative injury claim against former employers and their insurers. The Workers' Compensation Appeals Board (WCAB) affirmed an award to the applicant, finding California had jurisdiction based on the applicant's games played in the state and, potentially, a contract of hire in California. Defendants argued California lacked jurisdiction, citing *Federal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)*, which held that a single game did not create a substantial connection. However, the WCAB distinguished this case, finding the applicant's California exposure more than "de minimis" and noting the applicant's testimony about an injury sustained in California. One commissioner dissented, arguing the applicant's California games constituted less than 8% of his career and thus did not establish a "legitimate and substantial connection" for jurisdiction under *Johnson*.

WCABcumulative industrial injuryprofessional basketball playerextraterritorial provisionsde minimiscontract of hirejurisdiction14th Amendmentdue processliability
References
22
Case No. ADJ8501790
Regular
Jul 29, 2015

Kelly Chase vs. St. Louis Blues Hockey Club, Federal Insurance Company

The Workers' Compensation Appeals Board (WCAB) reversed a prior finding of industrial injury for a professional hockey player against the St. Louis Blues. The WCAB found insufficient connection to California for jurisdiction, citing the player's limited games in the state compared to his overall career. This decision followed the precedent set in *Federal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)*, which requires a legitimate and substantial connection to the state for jurisdiction. The WCAB concluded that 21 games out of 485 did not meet this standard for a cumulative injury claim.

WCABSt. Louis Blues Hockey ClubFederal Insurance CompanyADJ8501790Opinion and Decision After Reconsiderationcumulative industrial injuryprofessional hockey playersubject matter jurisdictionstatute of limitationssubstantial medical evidence
References
1
Case No. ADJ6857928
Regular
Apr 05, 2015

CALVIN COLLINS vs. ATLANTA FALCONS, TRAVELERS INSURANCE COMPANY

The Workers' Compensation Appeals Board (WCAB) affirmed the Administrative Law Judge's (ALJ) decisions to deny enforcement of a compromise and release agreement and to decline jurisdiction over the applicant's claim. The WCAB found that the applicant's minimal contacts with California, consisting of playing only six games over his seven-year career, were insufficient to establish a legitimate and substantial connection to the alleged cumulative trauma injury. Therefore, asserting California jurisdiction would violate the employer's due process rights. The WCAB referenced the *Johnson* case, holding that such limited exposure does not create a substantial California interest.

Workers' Compensation Appeals BoardCompromise and ReleaseSubject Matter JurisdictionCumulative Trauma InjuryProfessional AthleteDe Minimis ConnectionDue ProcessLegitimate and Substantial ConnectionLabor Code 3600.5Extraterritorial Provisions
References
10
Case No. ADJ7469776
Regular
Jun 01, 2015

PAUL PALMER vs. KANSAS CITY CHIEFS, TRAVELERS PROPERTY CASUALTY COMPANY OF AMERICA

This case concerns whether California workers' compensation jurisdiction applies to an out-of-state professional football player's cumulative injury claim. The Workers' Compensation Appeals Board (WCAB) denied the applicant's petition for reconsideration, affirming the WCJ's finding that the applicant's minimal contact with California (5 out of 62 games) did not establish a sufficient connection for due process under *Federal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)*. The majority found that California lacked a legitimate and substantial interest in adjudicating the claim, deeming the applicant's contact "de minimis." Commissioner Sweeney dissented, arguing that California has a substantial interest in injured workers and that the applicant's contact was more than de minimis, thus supporting WCAB jurisdiction.

WCABPaul PalmerKansas City ChiefsTravelers Property Casualty Company of AmericaADJ7469776Petition for ReconsiderationFindings of FactAdministrative Law JudgeWCJFederal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)
References
2
Case No. ADJ8260810
Regular
Jul 07, 2015

DANIEL STRYZINSKI vs. NEW YORK JETS, THE TRAVELERS INDEMNITY COMPANY, KANSAS CITY CHIEFS, TIG INSURANCE, ATLANTA FALCONS, PITTSBURGH STEELERS

The Workers' Compensation Appeals Board (WCAB) denied an applicant's petition for reconsideration, affirming the administrative law judge's (ALJ) decision that California lacks jurisdiction over his cumulative trauma claim. The ALJ found that the applicant's participation in only 21 out of 275 professional football games played in California did not establish a sufficient connection to the state for due process purposes. The majority opinion relied on the *Federal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)* case, holding that California's interest was not substantial enough to assert jurisdiction given the applicant's lack of residency and hiring in the state. A dissenting opinion argued that California has a legitimate interest in compensating workers injured within its borders and that the applicant's connection was more than "de minimis," thus supporting WCAB jurisdiction.

StryzinskiProfessional AthleteCumulative TraumaJurisdictionDue ProcessFederal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)Legitimate and Substantial InterestDe MinimisExtraterritorial ProvisionsLabor Code section 3600.5
References
2
Case No. MISSING
Regular Panel Decision

Claim of Williams v. 21st Century Restaurant Co.

The claimant sustained multiple compensable head, neck, back, and shoulder injuries on June 13, 1974, September 20, 1974, and October 23, 1974, resulting in total disability. The central issue on appeal was whether there was substantial evidence to support the Workers' Compensation Board's finding of a causal connection between all these accidents, specifically the June 13, 1974 accident, and the claimant's disability. Medical evidence included reports from an attending physician and Dr. Blackwell, and testimony from board physician Dr. Harrow, who stated the injuries were 'one superimposed upon the other' with 'a cumulative end result'. The court affirmed the board's decision, concluding that the appeal lacked merit and substantial evidence supported a common causal connection to the claimant's disability.

Workers' CompensationTotal DisabilityCausal ConnectionPost-concussion SyndromeMedical EvidenceSubstantial EvidenceAppellate ReviewMultiple InjuriesCumulative Injury
References
0
Case No. ADJ9084481
Regular
Dec 06, 2017

AMAURY TELEMACO vs. PHILADELPHIA PHILLIES, ACE AMERICAN INSURANCE COMPANY, ARIZONA DIAMONDBACKS, VIRGINIA SURETY COMPANY

The Appeals Board granted reconsideration of a WCJ's finding of no subject matter jurisdiction, acknowledging that the applicant played 19 games in California during his baseball career. However, the Board intends to find that this minimal connection, absent a hiring in California, does not create a substantial and legitimate interest for California to adjudicate the claim under the *Johnson* due process standard. The Board will allow further briefing on the application of *Johnson* and the relevant statutory amendment regarding professional athletes.

Subject Matter JurisdictionLabor Code section 3600.5(a)Labor Code section 5305Hiring in CaliforniaCumulative InjuryConstitutional Due ProcessFederal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)Substantial and Legitimate ConnectionProfessional Baseball PlayerInjurious Exposure
References
9
Case No. ADJ8025362
Regular
Apr 20, 2015

JOHN WALLACE vs. PHOENIX SUNS, TIG INSURANCE

The Workers' Compensation Appeals Board reversed a prior ruling, finding California lacks sufficient connection to a professional basketball player's cumulative injury claim. The Board held that playing a small percentage of games in California and receiving minor medical treatment does not establish a legitimate and substantial interest for the state to exercise jurisdiction, citing the *Federal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)* precedent. Consequently, the applicant takes nothing on his claim.

Workers' Compensation Appeals BoardPhoenix SunsTIG InsuranceJohn WallaceLabor Code Section 3600.5(b)Federal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)jurisdictionprofessional athletecumulative industrial injurylegitimate and substantial connection
References
4
Case No. ADJ8636173
Regular
Jun 14, 2016

MICHAEL WILSON vs. HARLEM GLOBETROTTERS INTERNATIONAL, TRAVELERS PROPERTY CASUALTY COMPANY OF AMERICA

This case involved a workers' compensation claim by Michael Wilson, a former Harlem Globetrotters player, against his employer and insurer. The Workers' Compensation Appeals Board (WCAB) reversed a prior ruling, finding that California lacked sufficient connection to Wilson's injury to exercise jurisdiction. The WCAB cited *Federal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)*, concluding that Wilson's temporary participation in games in California did not create a legitimate and substantial interest for the state to adjudicate the claim. Therefore, Wilson took nothing on his claim.

Workers' Compensation Appeals BoardHarlem GlobetrottersTravelers Property Casualty Company of Americaindustrial injuryprofessional basketball playerpermanent disabilityfuture medical treatmentLabor Code section 3600.5(b)reciprocity provisionsArizona Revised Statute 23-904
References
12
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