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Case Law Database

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

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. ADJ8649434
Regular
Apr 15, 2015

Carlos Delgado vs. New York Mets, ACE AMERICAN INSURANCE COMPANY

This case involves a professional baseball player's cumulative injury claim against the New York Mets. The Workers' Compensation Appeals Board (WCAB) reversed a prior ruling, finding California lacks jurisdiction. The applicant, a non-resident, played only 138 games out of over 2,000 in California, with no employment contracts or residence in the state. The Board applied the *Johnson* precedent, determining California's connection to the injury was insufficient to support jurisdiction, and the applicant took nothing.

WCAB jurisdictioncumulative industrial injuryprofessional baseball playerFederal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)legitimate and substantial interestseasonal employeeemployment contracts outside Californiaresident of Puerto Ricomajor league games in Californiaquantitative factor
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. ADJ11428234
Regular
Oct 17, 2025

RAMON COLLADO vs. CALIFORNIA DEPARTMENT OF CORRECTIONS, CENTINELA STATE PRISON

The Workers' Compensation Appeals Board granted reconsideration to study the factual and legal issues in Ramon Collado's case against the California Department of Corrections and Centinela State Prison. Collado sought reconsideration of a WCJ's Findings and Order from July 28, 2021, which concluded he failed to prove an industrially caused heart/hypertension injury between December 20, 2012, and August 14, 2018. The Board found the Qualified Medical Evaluator's opinion on whether Collado's condition was an aggravation or mere exacerbation of prior injuries was unclear and contradictory, failing to constitute substantial medical evidence. Consequently, the Board rescinded the WCJ's decision and returned the matter to the trial level for further proceedings, including the development of the medical record and a determination on the applicability of Labor Code section 3212 presumptions.

Workers Compensation Appeals BoardRamon ColladoCalifornia Department of CorrectionsCentinela State PrisonState Compensation Insurance FundOpinion and Decision After ReconsiderationFindings and Orderworkers' compensation administrative law judgeindustrially caused injuryexacerbation
References
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
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
Case No. SFO 0481391, SFO 0489565
Regular
Jun 18, 2008

LEANNA LEE vs. SOURCECORP, INC., ST. PAUL TRAVELERS/TRAVELERS PROPERTY CASUALTY CO. OF AMERICA

This case returns to the trial level for further proceedings and a new decision after the Appeals Board found the original decision inconsistent with recent case law regarding the combination of separate injuries. The Board rescinded the previous award, highlighting the need to re-evaluate permanent disability based on current apportionment principles and to address the issue of overlap in the applicant's disabilities. The original decision also failed to address specific claims like copy service charges, which the WCJ must now consider.

Workers' Compensation Appeals BoardReconsiderationFindings Award OrderIndustrial InjuryCumulative TraumaTemporary Disability IndemnityPermanent DisabilityApportionmentLabor Code section 4664Labor Code section 4663
References
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