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

Case No. ADJ7236952
Regular
Dec 18, 2014

JONATHAN (JON) VAUGHN vs. SEATTLE SEAHAWKS

In this case, the Workers' Compensation Appeals Board (WCAB) affirmed a prior decision finding it lacked jurisdiction over a professional football player's cumulative injury claim against the Seattle Seahawks. The applicant, who never resided in California and whose employment contracts were not made there, argued that a small number of games played in California were sufficient to establish jurisdiction. The Board, relying on the precedent set in *Federal Ins. Co. v. Workers' Comp. Appeals Bd. (Johnson)*, determined that the connection between the applicant's work in California and his injury was de minimis. Therefore, California has no legitimate interest to support the exercise of WCAB jurisdiction.

Workers' Compensation Appeals BoardSeattle SeahawksCumulative InjuryJurisdictionDe MinimisJohnsonProfessional Football PlayerLabor Code Section 5500.5McKinleyDuty Days
References
2
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
References
32
Case No. ADJ7106696
Regular
Oct 09, 2012

JAMAL CLARK vs. SEATTLE SEAHAWKS, Permissibly SelfInsured, Administered by CMS, NFL EUROPE, TIG INSURANCE, Administered by REM

This Workers' Compensation Appeals Board case, *Jamal Clark v. Seattle Seahawks*, involves a defendant's petition for reconsideration of a July 16, 2012, award. The Board has granted this petition to allow for further study of the factual and legal issues presented. The Board believes this is necessary to thoroughly understand the record and render a just decision. Pending the Decision After Reconsideration, all filings must be submitted in writing directly to the Commissioners' office in San Francisco, not to district offices or through e-filing.

Workers' Compensation Appeals BoardPetition for ReconsiderationFindings Award and OrdersStatutory Time ConstraintsFactual and Legal IssuesJust and Reasoned DecisionDecision After ReconsiderationOffice of the CommissionersElectronic Adjudication Management SystemVan Nuys District Office
References
0
Case No. ADJ7233546
Regular
Apr 12, 2013

REGINALD SWINTON vs. ARIZONA CARDINALS, GREAT DIVIDE INSURANCE COMPANY, BERKLEY SPECIALTY UNDERWRITING MANAGERS, LLC, DALLAS COWBOYS, TRAVELERS, SEATTLE SEAHAWKS, PSI

This Workers' Compensation Appeals Board decision affirms a prior administrative law judge's finding in the case of Reginald Swinton. The Board adopted the judge's report and recommendation without further elaboration. Therefore, the original May 31, 2012, Findings and Order remain in effect. The specific details of the claim against the Arizona Cardinals, Dallas Cowboys, and Seattle Seahawks were not detailed in this excerpt.

Reginald SwintonArizona CardinalsGreat Divide Insurance CompanyBerkley Specialty Underwriting ManagersDallas CowboysTravelersSeattle SeahawksPSIADJ7233546Anaheim District Office
References
0
Case No. ADJ3461600 (ANA 0373630)
Regular
May 20, 2009

David Thompson vs. Seattle Supersonics, Washington State Department of Labor & Industry

This case involves a professional basketball player's workers' compensation claim for cumulative trauma injury sustained while playing in California for the Seattle Supersonics. The California Workers' Compensation Appeals Board (WCAB) rescinded a prior award due to a lack of established personal jurisdiction over the Washington State Department of Labor & Industries and a failure to prove the Seattle Supersonics were lawfully insured or self-insured in California. The case is returned to the trial level to determine if the Supersonics met their statutory obligations for workers' compensation coverage in the state. The WCAB will also address remaining contentions regarding apportionment and limitations on liability.

Cumulative traumaProfessional basketballPersonal jurisdictionWashington L&ISpecial appearanceMotion to quashMinimum contactsStatute of limitationsApportionmentLabor Code section 3700
References
11
Case No. ADJ1303018 (ANA 0382837)
Regular
May 18, 2009

GEORGE T. JOHNSON vs. NEW JERSEY NETS, INA/ACE USA, SEATTLE SUPERSONICS, WASHINGTON STATE DEPARTMENT OF LABOR & INDUSTRY

The Workers' Compensation Appeals Board (WCAB) rescinded a prior ruling finding California had jurisdiction over Washington State Department of Labor & Industries (Washington L&I) in a claim by former NBA player George T. Johnson. The WCAB determined personal jurisdiction over Washington L&I was not established and that the issue is moot unless Washington L&I was duly authorized to provide workers' compensation insurance in California per Labor Code section 3700. The case is returned to the trial level to determine if the employer, Seattle Supersonics, was lawfully insured or self-insured in California during the alleged injury period, which could result in Seattle being held liable as an uninsured employer.

Workers' Compensation Appeals BoardWashington State Department of Labor & IndustriesSeattle Supersonicsjurisdictionsubject matter jurisdictionpersonal jurisdictioncumulative trauma injuryprofessional basketball playeruninsured employerduly authorized insurer
References
11
Case No. ADJ2250216 (AHM 0151781)
Regular
Nov 25, 2013

JOHN RANDLE vs. SEATTLE SEAHAWKS, MINNESOTA VIKINGS

The Workers' Compensation Appeals Board rescinded a previous award, finding that while jurisdiction was proper and the statute of limitations was not a bar, the original decision failed to adequately address several issues. Specifically, the Board remanded the case to determine the proper defendant(s) and excluded the applicant's heart condition from permanent disability ratings due to insufficient medical evidence of industrial causation. The WCJ must also resolve other outstanding issues raised at trial before issuing a new decision.

John RandleSeattle SeahawksMinnesota Vikingsjurisdictioncontract of hirestatute of limitationscumulative traumaagreed medical evaluatorspermanent disabilityapportionment
References
28
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. ADJ7189565
Regular
Mar 28, 2013

CHARTRIC DARBY vs. DETROIT LIONS, LIBERTY MUTUAL INSURANCE CO., SEATTLE SEAHAWKS

The Workers' Compensation Appeals Board denied Liberty Mutual's petition for removal, finding that the insurer failed to demonstrate the extraordinary circumstances required for such a request. The Board determined that the insurer did not establish irreparable harm, as reconsideration after a final award would be an adequate remedy. The case was returned to the trial level for a new judge to consider evidence related to an ongoing grievance proceeding, provided it meets specific evidentiary standards. The new judge will then decide how, if at all, the grievance proceeding impacts the applicant's workers' compensation claim.

Petition for RemovalMandatory Settlement ConferenceGrievance ProceedingCollective Bargaining AgreementChoice of ForumChoice of LawIrreparable HarmReconsiderationWCJMedical-Legal Reports
References
1
Case No. ADJ 6705983
Regular
May 14, 2012

Jacob Green vs. Seattle Seahawks, San Francisco 49ers, National Union Fire Insurance Co. of Pittsburgh, Pennsylvania

The Workers' Compensation Appeals Board granted reconsideration of a Findings and Award concerning Jacob Green's cumulative injury claim as a professional athlete. The defendant insurer, National Union Fire Insurance Company, argued the award lacked substantial evidence and listed eight specific errors by the administrative law judge. Reconsideration was granted primarily to allow the defendant to submit trial transcripts for review.

Workers' Compensation Appeals Boardcumulative injurypermanent disabilityfuture medical carestatute of limitationsFindings and AwardFindings and AwardMinutes of HearingSummary of Evidenceprofessional athlete
References
0
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