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

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
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
Case No. ADJ8613780
Regular
Jan 12, 2017

GLENN PARKER vs. KANSAS CITY CHIEFS, TIG/FAIRMONT PREMIER INSURANCE COMPANY, NEW YORK GIANTS, GULF/TRAVELERS INSURANCE COMPANY, BUFFALO BILLS, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION for RELIANCE INSURANCE COMPANY

This case concerns whether California has sufficient jurisdiction to hear a workers' compensation claim for cumulative injury filed by a former professional football player. The applicant played 12 out of 176 total games in California, which the majority found to be a de minimis contact insufficient for California to assert jurisdiction due to due process concerns, citing the *Johnson* case. The Board affirmed the trial judge's decision to deny jurisdiction, while also correcting a clerical error regarding the insurer. A dissenting commissioner argued that California's interest in protecting workers injured within the state is substantial and that the applicant's contacts were not de minimis.

WCABcumulative industrial injuryprofessional athletede minimis California contactsdue processsubject matter jurisdictionFederal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)constitutional due processextraterritorial provisionsstatutory exemption
References
Case No. ADJ712966 (LAO 0882887) ADJ4304736 (LAO 0882888)
Regular
Nov 09, 2012

JOSE SILVA vs. ENTERTAINMENT PARTNERS, CHARTIS

The WCAB granted reconsideration to amend a prior award, deleting a finding of injury to the applicant's right lower extremity based on the agreed medical examiner's opinion. The Board affirmed the original award in all other respects, including the finding of industrial injury to the psyche and lumbar spine and the 24% permanent disability rating. The WCAB also denied the defendant's request for credit for temporary disability overpayment, finding it within their discretion and noting the de minimis amount and applicant's good faith.

Workers' Compensation Appeals BoardReconsiderationFindings Award and OrderIndustrial InjuryPsycheLumbar SpineRight Lower ExtremityPermanent DisabilityTemporary Disability IndemnityAgreed Medical Examiner
References
Case No. ADJ7793914
Regular
Sep 10, 2014

KEITH BOOTH vs. CHICAGO BULLS, TIG INSURANCE

The Appeals Board reversed the WCJ's finding of jurisdiction, holding that the applicant did not present substantial evidence of a cumulative industrial injury incurred in California. Despite participating in practices on three occasions, the Board found these contacts insufficient to establish California's legitimate interest in adjudicating the claim, citing the *Johnson* case's standard. The Board determined that the applicant's participation in practices in California was de minimis and did not warrant the application of California workers' compensation law. Therefore, the applicant was ordered to take nothing on his claim.

cumulative traumaworkers' compensation jurisdictionprofessional athleteCalifornia contactde minimisdue processlegitimate interestsports injuryindustrial injuryPetition for Reconsideration
References
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
Case No. ADJ8128265
Regular
Feb 05, 2015

WILLIAM GARNETT vs. DALLAS BASKETBALL LTD (DALLAS MAVERICKS), INSURANCE COMPANY OF NORTH AMERICA/ACE USA, INDIANA PACERS

The Workers' Compensation Appeals Board (WCAB) affirmed a decision denying jurisdiction over applicant William Garnett's cumulative trauma claim. Garnett, a former professional basketball player, argued he sustained injury while playing for the Dallas Mavericks and Indiana Pacers, with over 20 games played in California. However, the WCAB found Garnett's contacts with California insufficient, deeming the 22 games played as de minimis based on the *Johnson* precedent. The Board concluded that constitutional due process required a sufficient relationship between the injury and the state, which was not met here.

Workers' Compensation Appeals BoardCumulative TraumaJurisdictionDe MinimisJohnsonMcKinleyProfessional AthleteNBAIndiana PacersDallas Mavericks
References
Case No. ADJ9094930
Regular
Nov 08, 2018

ROBERT STANIFER vs. CHICAGO CUBS; WASHINGTON NATIONALS aka MONTREAL EXPOS; ACE AMERICAN INSURANCE COMPANY/CHUBB;BOSTON RED SOX; TRAVELERS INSURANCE COMPANY

The Workers' Compensation Appeals Board (WCAB) affirmed the decision to deny applicant's claim for cumulative trauma injury, finding insufficient connection to California. While applicant claimed to be hired in California by Hiroshima Toyo Carp, that employer is not a party, precluding jurisdiction under Labor Code Section 5305. The WCAB determined that applicant's participation in 12 games in California out of 440 total games over 11 seasons was de minimis and insufficient to overcome defendants' due process objection. Therefore, the minimal contact with California did not justify requiring defendants to litigate the claim in this state.

Workers' Compensation Appeals BoardCumulative TraumaCalifornia ContactLabor Code Section 5305Subject Matter JurisdictionContract of HireDue ProcessFederal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)Professional AthleteDuty Days
References
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
Case No. ADJ2295331 (ANA 0397551)
Regular
Mar 17, 2014

WESLEY CARROLL vs. NEW ORLEANS SAINTS, LOUISIANA WORKERS' COMPENSATION CORPORATION, TRAVELERS INSURANCE

This case concerns a former professional football player seeking workers' compensation for cumulative industrial injury against the New Orleans Saints. The applicant argues California has jurisdiction because prior proceedings conclusively determined injury occurred in California and the *Johnson* precedent was misapplied. However, the Appeals Board affirmed the WCJ's finding that California lacks a substantial interest to justify jurisdiction, as the applicant's California work activities were de minimis, consisting of only five games played in the state over his career. The Board found that California's connection to the injury was insufficient to warrant applying its workers' compensation law, consistent with *Johnson*.

WCABPetition for ReconsiderationFindings And OrderTake NothingFindings Of FactSubstantial InterestJurisdictionCumulative Industrial InjuryProfessional Football PlayerWide Receiver
References
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