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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
2
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. ADJ10779733
Regular
Feb 26, 2020

THOMAS WILSON vs. FLORIDA MARLINS, ACE AMERICAN INSURANCE, SEDGWICK CLAIMS MANAGEMENT SERVICES

This case involves a professional athlete's workers' compensation claim where the central issue is whether California jurisdiction is precluded by Labor Code sections 3600.5(c) and (d) concerning out-of-state athletes. The Board found these exemptions inapplicable because the applicant had multiple California contracts of hire during his cumulative trauma injury period, aligning with California's general jurisdictional rules. The Board interpreted the intent of the statutory amendments to be the limitation of claims by out-of-state athletes with minimal California contacts, not those with established hire in the state. Therefore, the applicant's claim may proceed in California.

Labor Code Section 3600.5Professional Athlete ExceptionCumulative TraumaContract of HireJurisdictionOut-of-State EmployersCalifornia-Based TeamDuty DaysTemporary WorkLegislative Intent
References
13
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. ADJ8574285
Regular
Jan 24, 2017

CALE HULSE vs. CALGARY FLAMES, FEDERAL INSURANCE COMPANY

The Workers' Compensation Appeals Board reversed a prior award, finding California lacked subject matter jurisdiction over the applicant's cumulative trauma claim. The Board determined that the applicant, a professional hockey player, had insufficient connection to California, playing only 25-42 games out of over 848 total games. This minimal contact, insufficient for a legitimate and substantial interest, meant requiring the defendant to litigate in California would violate due process, as established in *Federal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)*. Therefore, the applicant was awarded nothing.

Workers Compensation Appeals BoardCalgary FlamesFederal Insurance CompanyCale HulseSubject Matter JurisdictionCumulative Trauma InjuryProfessional Hockey PlayerDue ProcessFederal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)Legitimate Interest
References
6
Case No. ADJ6857928
Regular
Apr 05, 2015

CALVIN COLLINS vs. ATLANTA FALCONS, TRAVELERS INSURANCE COMPANY

The Workers' Compensation Appeals Board (WCAB) affirmed the Administrative Law Judge's (ALJ) decisions to deny enforcement of a compromise and release agreement and to decline jurisdiction over the applicant's claim. The WCAB found that the applicant's minimal contacts with California, consisting of playing only six games over his seven-year career, were insufficient to establish a legitimate and substantial connection to the alleged cumulative trauma injury. Therefore, asserting California jurisdiction would violate the employer's due process rights. The WCAB referenced the *Johnson* case, holding that such limited exposure does not create a substantial California interest.

Workers' Compensation Appeals BoardCompromise and ReleaseSubject Matter JurisdictionCumulative Trauma InjuryProfessional AthleteDe Minimis ConnectionDue ProcessLegitimate and Substantial ConnectionLabor Code 3600.5Extraterritorial Provisions
References
10
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. 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. ADJ 8937991
Regular
May 23, 2017

ANTONIO PIERCE vs. WASHINGTON REDSKINS, ACE AMERICAN INSURANCE AND TRAVELERS, NEW YORK FOOTBALL GIANTS, INC., GREAT DIVIDE INSURANCE COMPANY

This case concerns whether the California Workers' Compensation Appeals Board (WCAB) has jurisdiction over a professional football player's cumulative injury claim. The applicant asserts he was hired in California by the Washington Redskins and New York Football Giants, Inc., triggering WCAB jurisdiction. Defendants argued against jurisdiction, citing limited California contacts and employment contracts specifying other state laws. The WCAB affirmed the judge's finding of jurisdiction, holding that the applicant's hiring in California is sufficient to establish subject matter jurisdiction under Labor Code sections 3600.5 and 5305, irrespective of other contacts.

Workers' Compensation Appeals BoardAntonio PierceWashington RedskinsACE American InsuranceTravelersNew York Football GiantsGreat Divide Insurance Companyjurisdictioncontract of hireFederal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson)
References
30
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