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

Case No. ADJ7041227
Regular
Aug 09, 2017

GERALD PADDIO vs. CLEVELAND CAVALIERS, SEATTLE SUPERSONICS, INDIANA PACERS, WASHINGTON BULLETS/WASHINGTON WIZARDS, TIG INSURANCE, NEW YORK KNICKERBOCKERS, CHICAGO ROCKERS, LAS VEGAS SLAM/ CHICAGO SKYLINERS, TRAVELERS INDEMNITY COMPANY

The Workers' Compensation Appeals Board denied Travelers Indemnity Company's petition for reconsideration, affirming its subject matter jurisdiction over applicant Gerald Paddio's cumulative injury claim. The Board found that Paddio's hiring as a professional basketball player in California, through his agent accepting an offer in San Francisco, established jurisdiction under Labor Code sections 3600.5(a) and 5305. The Board also noted that the issue of potential exemption from California law, raised by the defendant, was not ripe for appeal and must be addressed at the trial level. All other issues remain deferred for determination by a Workers' Compensation Judge.

Subject matter jurisdictionLabor Code section 3600.5Labor Code section 5305Contract of hireProfessional basketball playerCumulative industrial injuryPetition for reconsiderationDenial of petitionAdministrative law judgeWorkers' Compensation Appeals Board
References
Case No. ADJ13302605; ADJ15813943
Regular
Mar 07, 2023

MATTHEW WARE vs. ARIZONA CARDINALS FOOTBALL CLUB, LLC, GREAT DIVIDE INSURANCE COMPANY C/O BERKLEY ENTERTAINMENT

The Workers' Compensation Appeals Board granted the defendant's Petition for Removal, reversing the WCJ's order to set the case for a Mandatory Settlement Conference on all issues. The Board found good cause to bifurcate and try the threshold issues of California subject matter and personal jurisdiction first. Bifurcating these jurisdictional issues is deemed more efficient, as a favorable ruling for the defendant would avoid further litigation. This decision prioritizes an expedited resolution of jurisdiction to facilitate the prompt delivery of potential benefits.

Petition for RemovalMandatory Settlement ConferenceBifurcationJurisdictionSubject Matter JurisdictionPersonal JurisdictionSpecial AppearanceDeclaration of ReadinessDiscoveryGood Cause
References
Case No. ADJ4661829 (ANA 0401410)
Regular
Dec 12, 2011

Vaughn Booker vs. Cincinnati Bengals, Kansas City Chiefs, Travelers Insurance Co., TIG Insurance Co., Green Bay Packers, Zurich American Insurance Co.

The Workers' Compensation Appeals Board rescinded an award finding jurisdiction over the Cincinnati Bengals, ruling that playing one game in California over three seasons does not constitute "regularly employed" for territorial jurisdiction. The Board found that all conditions under Labor Code section 3600.5(b) were met, establishing that the applicant's employment in California was temporary and covered by Ohio's workers' compensation laws. Therefore, California lacks subject matter jurisdiction over the claim against the Bengals. The case was returned to the trial level to determine jurisdiction over other defendants.

Subject Matter JurisdictionLabor Code Section 3600.5(a)Labor Code Section 3600.5(b)Territorial JurisdictionExtra-Territorial Jurisdiction"Regularly Employed"Temporary EmploymentReciprocityOhio Workers' Compensation ActCumulative Injury
References
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
Case No. ADJ11706407
Regular
Apr 15, 2025

Matthew Hatchette vs. Oakland Raiders, TIG/Fairmont Premier Insurance Company, Jacksonville Jaguars, ACE American Insurance Company, New York Jets, USF&G, Chubb, Pacific Employers Insurance

This case concerns Matthew Hatchette, a former professional football player, and his claims of continuous trauma injuries against multiple NFL teams and their insurers. Defendant Jacksonville Jaguars filed a Petition for Reconsideration challenging the Workers' Compensation Administrative Law Judge's (WCJ) findings regarding jurisdiction and the applicability of res judicata. The Workers' Compensation Appeals Board (WCAB) granted the petition to conduct a thorough review of the factual and legal issues, thereby deferring a final decision on the merits. The Board's decision also addressed the timeliness of the petition under the recently amended Labor Code section 5909.

Workers' Compensation Appeals BoardMatthew HatchetteOakland RaidersJacksonville JaguarsNew York JetsTIG/Fairmont Premier Insurance CompanyChubbUSF&GGallagher Bassett ServicesZenith Insurance Company
References
Case No. ADJ10184700
Regular
Nov 29, 2017

JONATHAN PARKER vs. INDY FUEL HOCKEY, GREAT DIVIDE INSURANCE COMPANY

This case involves a defendant insurance company seeking reconsideration of a WCAB decision finding jurisdiction over a professional hockey player's injury claim. The defendant argued the WCAB lacked personal jurisdiction, but the Board denied reconsideration. The defendant waived its objection to personal jurisdiction by failing to timely raise it and instead engaging in discovery and litigating subject matter jurisdiction. Subsequent actions, such as filing a Declaration of Readiness to Proceed and participating in hearings without specifying a special appearance for personal jurisdiction, constituted a general appearance. Therefore, the WCJ's original decision finding jurisdiction was affirmed.

Workers Compensation Appeals BoardIndy Fuel HockeyGreat Divide Insurance CompanyADJ10184700Petition for ReconsiderationPersonal JurisdictionSubject Matter JurisdictionLabor Code 3600.5(a)Labor Code 5301Labor Code 5305
References
Case No. ADJ18315308
Regular
May 09, 2025

CURTIS MADDEN III vs. SEATTLE SEAHAWKS, VIVIAN EBERLE

The Workers' Compensation Appeals Board (WCAB) affirmed the decision that California has subject matter jurisdiction over Curtis Madden III's industrial injury claim against the Seattle Seahawks. The jurisdiction was established because Madden accepted a verbal offer of employment in California, creating a valid contract for hire under state law. The WCAB ruled that the claim is not preempted by federal labor law as its resolution does not require interpreting the Collective Bargaining Agreement. Minor amendments were made to the factual findings to clarify that injury was 'claimed' rather than 'sustained' and to conform the listed body parts.

WCABjurisdictioncollective bargaining agreementNFLNFLPALMRApreemptioncontract of hireprofessional athletesubject matter jurisdiction
References
Case No. ADJ7828286
Regular
Oct 09, 2013

REGINALD GERMANY vs. BUFFALO BILLS, TRAVELERS INSURANCE COMPANY

The Workers' Compensation Appeals Board (WCAB) granted reconsideration, rescinding the prior decision that California lacked jurisdiction over the applicant's cumulative trauma injury claim. The WCAB found that the prior judge improperly applied personal jurisdiction principles. The case is returned for further proceedings to determine if defendants are exempt from WCAB jurisdiction under Labor Code section 3600.5(b) or if jurisdiction should be declined based on a mandatory forum selection clause and limited connection to California, as established in relevant en banc decisions.

Workers' Compensation Appeals BoardCumulative Trauma InjuryJurisdictionProfessional Football PlayerMcKinley v. Arizona CardinalsLabor Code Section 3600.5(b)Carroll v. Cincinnati BrownsForum Selection ClauseLimited Connection to CaliforniaExtraterritorial Provisions
References
Case No. ADJ18852673
Regular
Jul 14, 2025

Harrison P. Wenson vs. Los Angeles Angels, Ace American Insurance Company/Chubb

Applicant Harrison P. Wenson sought reconsideration of a WCJ's April 14, 2025, Findings of Fact and Order, which found no California subject matter jurisdiction over his cumulative trauma claim. Wenson argued jurisdiction based on Labor Code section 3600.5(d) exceptions, the defendant being a California employer, and his employment with a California-based team. The Appeals Board granted the petition for reconsideration to further study the jurisdictional issue, deferring a final decision after reconsideration.

Cumulative traumaSubject matter jurisdictionProfessional athleteLabor Code section 3600.5(d)Employer controlCalifornia-based teamContract of hireDuty daysSignificant connectionNexus
References
Case No. ADJ9531454 MF ADJ9531455
Regular
Dec 03, 2018

MOHAMMAD MORADI vs. NORTHWEST COLORADO TRANSPORT, LLC

The Workers' Compensation Appeals Board (WCAB) rescinded the finding of subject matter jurisdiction, determining that the applicant's contract of hire was concluded in North Dakota, not California, as per the written employment agreement signed there. Consequently, the WCAB lacks jurisdiction under Labor Code sections 3600.5(a) and 5305, which require the contract of hire to be made in California for out-of-state injuries. The WCAB's decision was influenced by the appellate court's ruling in *Tripplett*, which emphasized that a written employment contract signed out-of-state supersedes earlier oral agreements for jurisdictional purposes. As a result, the applicant will take nothing on his claims.

Workers' Compensation Appeals BoardSubject Matter JurisdictionPersonal JurisdictionContract of HireConditions SubsequentGeneral AppearanceWaiverLabor Code Section 5305Industrial InjuryNorth Dakota
References
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