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

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
14
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. 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. 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
8
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
7
Case No. ADJ8196440
Regular
May 29, 2015

ADAM BURT vs. CAROLINA HURRICANES, ATLANTA THRESHERS, PHILADELPHIA FLYERS, FEDERAL INSURANCE COMPANY

This case involves the insurer of a former employer of a professional hockey player seeking reconsideration of a prior WCAB decision. The WCAB had reversed a judge's finding that the applicant's California contacts were de minimis and that California jurisdiction should not be exercised. The insurer argued that the injury did not legally occur in California and that imposing liability would deny due process. The WCAB denied the petition for reconsideration, upholding its prior decision. One commissioner dissented, preferring to reinstate the original judge's findings.

Workers' Compensation Appeals BoardPetition for ReconsiderationCumulative Industrial InjuryProfessional Hockey PlayerDe Minimis ContactsJurisdictionDue ProcessDissenting OpinionOpinion and Order DenyingFindings and Order
References
1
Case No. ADJ8710981
Regular
Mar 25, 2015

PETER FORSBERG vs. NASHVILLE PREDATORS, COLORADO AVALANCHE, PHILADELPHIA FLYERS, FEDERAL INSURANCE COMPANY

The Workers' Compensation Appeals Board (WCAB) reinstated and affirmed its jurisdiction over Peter Forsberg's cumulative injury claim. The WCAB found that California has a legitimate and substantial interest in adjudicating claims for injuries sustained within the state, and Forsberg's work in California was more than "de minimis" to his cumulative trauma injury. This decision reversed a prior ruling that had denied jurisdiction, finding that the defendant did not prove statutory exemption and that due process concerns were not violated. The case was returned for further proceedings, with a dissenting opinion arguing that Forsberg's limited California contacts were insufficient to establish jurisdiction.

Cumulative injuryProfessional hockey playerWorkers' Compensation Appeals BoardJurisdictionFederal Insurance CompanyColorado AvalancheNashville PredatorsPhiladelphia FlyersDe minimis connectionLegitimate interest
References
23
Case No. ADJ8552834
Regular
Aug 24, 2015

JOHN SKORUPAN vs. NEW YORK GIANTS, ACE USA INSURANCE

The Workers' Compensation Appeals Board (WCAB) granted reconsideration to clarify its jurisdiction over applicant John Skorupan's cumulative industrial injury claim against the New York Giants. The WCAB affirmed the administrative law judge's (ALJ) finding that while the WCAB has personal jurisdiction, California lacks a legitimate and substantial interest to exercise jurisdiction over the claim, citing the *Federal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)* precedent. This decision hinges on the applicant's minimal California contacts (5 games out of 141 played) not establishing a sufficient connection for due process. Commissioner Sweeney dissented, arguing that the applicant's more than de minimis exposure in California and the state's public policy of protecting injured workers should support jurisdiction.

Workers' Compensation Appeals Boardcumulative industrial injuryprofessional athleteoutside linebackerspecial teamsFederal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)de minimis California contactsconstitutional due processPetition for ReconsiderationWCJ
References
1
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
5
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
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