What the panel ordered
Petition for Reconsideration denied.
This docket was decided more than once. Shown here is the latest released decision; we also hold May 16, 2024.
What was disputed, and how it came out
Each issue the panel decided, with the reasoning it gave. An outcome is what this panel did on this record — not a rule, and not a prediction.
The Board found that the applicant's California contract of hire with the Los Angeles Rams conferred subject matter jurisdiction over the injury claim, making sections 3600.5(c) and (d) inapplicable to the Falcons. The Falcons' arguments relying on exemptions under these sections were rejected based on precedent and statutory interpretation.
The facts that decided it
What the panel treated as outcome-determinative, and which side it favoured.
Applicant entered into a California contract of hire with the Los Angeles Rams during the injury period.
Favours Applicant prevailed
This contract conferred subject matter jurisdiction to the California WCAB over the injury claim, making exemptions under Labor Code sections 3600.5(c) and (d) inapplicable.
The rules the panel named
Authorities as the decision cited them, with how this panel applied each one.
Labor Code sections 5305 and 3600.5(a); Hansell v. Arizona Diamondbacks (2022)
A contract of hire in California confers subject matter jurisdiction over workers' compensation claims even for out-of-state injuries.
The Board applied this standard to determine that the applicant's California contract of hire with the Los Angeles Rams conferred jurisdiction over the injury claim, making exemptions under sections 3600.5(c) and (d) inapplicable.
Grahe v. Philadelphia Phillies (2018); Riggs v. Miami Marlins (2022)
Exemptions under Labor Code section 3600.5(c) do not apply to athletes hired in California during the injury period.
The Board distinguished these cases as not involving California contracts of hire and found the Falcons' reliance on these exemptions misplaced.
From the decision · page 2The Atlanta Falcons acknowledge that while there may be subject matter jurisdiction, pursuant to prior WCAB panel decisions the Falcons should be dismissed as being exempt from these proceedings pursuant to Labor Code section 3600.5(c).
McKinley v. Arizona Cardinals (2013)
Choice of law/forum clauses in contracts do not override California's jurisdiction when there is a California contract of hire.
The Board found McKinley distinguishable because the applicant in that case had no California contract of hire, whereas here the applicant did, thus California jurisdiction applies despite choice of law/forum clauses.
From the decision · page 4The Falcons further contend that our decision in McKinley v. Arizona Cardinals (2013) 78 Cal.Comp.Cases 23 [2013 Cal. Wrk. Comp. LEXIS 2], writ den. sub nom. McKinley v. Workers' Comp. Appeals Bd. (2013) 78 Cal.Comp.Cases 872 [2013 Cal. Wrk. Comp. LEXIS 122] (Appeals Board en banc) requires that we enforce a choice of law/forum clause in the applicant's contracts with the Falcons. (Petition, at p. 4:10.) Defendant avers, "McKinley requires, just as do the previously cited cases of Grahe, supra; Riggs supra and Smith supra, that while Applicant may be able to maintain a viable claim against the club over whom he entered in to a contract of hire in California (the Rams); there is however no liability against the club over whom there is a reasonable choice of law and choice of forum selection clause and they cannot be held liable for the cumulative trauma claim." (Petition, at p. 4:23.)
The same issues, filtered across the whole corpus — or paste your own facts and let the search rank by factor match.
About this page
- A published decision of the California Workers' Compensation Appeals Board, taken apart by what it turned on. The Board publishes the decision itself; this page adds the extraction and quotes the passage behind every claim.
- The injured worker is not named here, and the case caption is not printed. Physicians appear as the decision names them, because a medical opinion is an act in a public proceeding.
- Issues, outcomes and weights were extracted by AI and released only where the source passage checked. Read the official decision before relying on anything here. Not legal advice.
- If you are named in this decision and want this page removed, write to privacy@similarcase.com.