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

Case No. ADJ7598160
Regular
Nov 19, 2014

MAURICE JOHNSON vs. PHILADELPHIA EAGLES, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION for RELIANCE INSURANCE COMPANY, in liquidation, FAIRMONT PREMIER INSURANCE COMPANY

The Workers' Compensation Appeals Board reversed a lower decision, finding California lacked jurisdiction over a professional football player's cumulative trauma claim against the Philadelphia Eagles. The Board held that playing only two games in California did not create a sufficient connection to the injury to warrant applying California law, citing *Federal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)*. The applicant's limited physical presence and routine pre/post-game treatment in California were deemed de minimis. Therefore, the applicant took nothing on his California WCAB claim.

CIGAPhiladelphia EaglesReliance Insurance Companycumulative traumaprofessional football playerjurisdictionFederal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)administrative law judgepermanent disabilityapportionment
References
16
Case No. ADJ8180232
Regular
Sep 13, 2017

HUBERT OLIVER vs. PHILADELPHIA EAGLES, ACE/ESIS, INDIANAPOLIS COLTS, TRAVELERS INDEMNITY COMPANY, HOUSTON OILERS, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION for HOME INSURANCE

The Workers' Compensation Appeals Board granted reconsideration to review a judge's finding of no California jurisdiction over a professional football player's injury claim. The Board will consider whether the applicant was hired in California and if playing two games here creates sufficient connection for jurisdiction under the *Johnson* decision. The applicant will be allowed to file a supplemental brief referencing trial transcripts, and all parties will have an opportunity to brief the Board's intention to rule on the sufficiency of California's interest in adjudicating the claim.

Workers' Compensation Appeals BoardCalifornia jurisdictionindustrial injuryprofessional football playeremployment contractssubject matter jurisdictionsupplemental briefingcumulative traumaFederal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)due process
References
6
Case No. ADJ14657802
Regular
Sep 19, 2022

STEVE LAUTER vs. BALTIMORE RAVENS FKA CLEVELAND BROWNS, PERMISSIBLY SELF-INSURED, ADMINISTERED BY BERKLEY ENTERTAINMENT, SAN DIEGO CHARGERS, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION FOR FREMONT INSURANCE, IN LIQUIDATION

The Workers' Compensation Appeals Board granted reconsideration of a prior ruling and amended a finding of fact. The Board affirmed that California lacked personal jurisdiction over the Baltimore Ravens (formerly Cleveland Browns) for applicant's claimed injuries. The decision found no evidence of a contract formed in California and that the applicant's activities with the Browns, including games played in California, occurred after his release and were not connected to his claimed injury. The Board also declined to disturb the WCJ's reliance on pre-2005 medical-legal procedures.

Workers' Compensation Appeals BoardPersonal JurisdictionSubject Matter JurisdictionMinimum ContactsSpecial AppearanceContract of HireOffer and AcceptanceOral ContractForum StateLabor Code Section 4062
References
22
Case No. ADJ8691809
Regular
Apr 14, 2017

NICOLE BORAGNO vs. STATE OF CALIFORNIA, CDCR - CENTRAL CALIFORNIA WOMEN'S FACILITY CHOWCHILLA, STATE COMPENSATION INSURANCE FUND/STATE CONTRACT SERVICES

This case involves Nicole Boragno's workers' compensation claim against the State of California, CDCR. The applicant sought reconsideration of a decision denying the admission of a supplemental medical report. The WCAB denied reconsideration, adopting the WCJ's report which found the supplemental report inadmissible. This was because discovery had closed at the mandatory settlement conference, and the defendant failed to establish good cause for introducing evidence not previously disclosed. The WCJ noted there was no change in circumstances to warrant the late-filed report, distinguishing it from precedent that allows such reports.

WORKERS' COMPENSATION APPEALS BOARDPetition for Reconsiderationmandatory settlement conferencediscovery closureLabor Code section 5502(d)(3)good causesupplemental reportPQMEapportionmenttimeliness
References
2
Case No. MISSING
Regular Panel Decision

Official Committee of Unsecured Creditors of 360networks (USA) Inc. v. Public Utilities Commission of California (In Re 360networks (USA) Inc.)

The Official Committee of Unsecured Creditors of 360networks (USA) Inc. (Debtors) initiated an adversary proceeding against the Public Utilities Commission of the State of California (CPUC) seeking to avoid certain fee payments as preferential transfers under the Bankruptcy Code. The CPUC moved to dismiss the action, asserting Eleventh Amendment sovereign immunity and arguing the court lacked jurisdiction. Judge Allan L. Gropper denied the CPUC's motion, concluding that the court holds in rem jurisdiction over the debtor's property in a preference action. The Court determined that the exercise of this jurisdiction would not offend state sovereignty, citing various forms of potential relief available, including the disallowance of claims by other California state instrumentalities.

Bankruptcy LawSovereign ImmunityEleventh AmendmentIn Rem JurisdictionPreference ActionMotion to DismissPublic Utilities CommissionCalifornia Environmental Quality ActDebtor-Creditor RelationsFederal Jurisdiction
References
45
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. 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. ADJ1888124 (SAL 0111884) ADJ3322590 (SAL 0079903)
Regular
Oct 20, 2016

MARIA NUNEZ vs. MANN PACKING COMPANY, INC., CALIFORNIA INSURANCE GUARANTEE ASSOCIATION For FREMONT COMPENSATION INSURANCE COMPANY, In Liquidation; STATE OF CALIFORNIA

This case concerns the California Insurance Guarantee Association's (CIGA) liability for an applicant's workers' compensation claims after Fremont Compensation Insurance Company became insolvent. CIGA argued it should be relieved of liability because the State of California, as the applicant's employer through IHSS, constituted "other insurance" under Insurance Code Section 1063.1. The Appeals Board affirmed the WCJ's decision, holding that the State of California does not qualify as "other insurance" under the relevant statutes. This distinction is based on the State not being required to obtain workers' compensation insurance or a certificate of self-insurance like private or other public employers.

CIGAFremont Compensation Insurance Companyliquidationlegally uninsuredother insuranceInsurance Code Section 1063.1covered claimsIn-Home Supportive Services (IHSS)statutory limitationsself-insurance
References
5
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. ADJ9146501
Regular
Feb 06, 2023

MARCUS ROBINSON vs. CHICAGO BEARS, FAIRMONT PREMIER INSURANCE COMPANY, ZENITH, TRAVELERS INDEMNITY COMPANY, MINNESOTA VIKINGS, GALLAGHER BASSETT SERVICES, BALTIMORE RAVENS

The Workers' Compensation Appeals Board affirmed a prior decision barring applicant Marcus Robinson's claim in California. The Board found that Robinson's cumulative trauma injury, sustained over a lengthy professional football career, lacked a sufficient connection to California. Despite Robinson playing four games and practicing once in California, this exposure constituted only about 3% of his career, similar to a prior case that found such a connection de minimis. The Board clarified that while statutory jurisdiction exists, exercising it here would violate due process.

WCABReconsiderationJohnsonCalifornia JurisdictionDue ProcessCumulative TraumaProfessional Football PlayerEmployment NexusDe MinimisStatutory Jurisdiction
References
3
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