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Case No. ADJ18315308
Regular
May 09, 2025

CURTIS MADDEN III vs. SEATTLE SEAHAWKS, VIVIAN EBERLE

The Workers' Compensation Appeals Board (WCAB) affirmed the decision that California has subject matter jurisdiction over Curtis Madden III's industrial injury claim against the Seattle Seahawks. The jurisdiction was established because Madden accepted a verbal offer of employment in California, creating a valid contract for hire under state law. The WCAB ruled that the claim is not preempted by federal labor law as its resolution does not require interpreting the Collective Bargaining Agreement. Minor amendments were made to the factual findings to clarify that injury was 'claimed' rather than 'sustained' and to conform the listed body parts.

WCABjurisdictioncollective bargaining agreementNFLNFLPALMRApreemptioncontract of hireprofessional athletesubject matter jurisdiction
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