What the panel ordered
Petitions for Reconsideration denied.
Petitions for Reconsideration filed by defendants and applicant; WCJ issued Findings and Order on January 2, 2024, after rescinding prior Findings and Order; matter reviewed by WCAB panel decision on March 13, 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 WCJ found and the panel adopted that the applicant entered into oral contracts of hire with the Rams and Seahawks in California, conferring subject matter jurisdiction under Labor Code section 3600.5(a).
From the decision · page 1In addition to the WCJ's well-reasoned Report, we observe the following. Defendant St. Louis Rams contend the court lacks jurisdiction over the defendant pursuant to Labor Code1 section 3600.5(c) because applicant had less than 20 percent of his duty days with the Rams. (Rams' Petition, dated January 19, 2023, at p. 6:11.) However, the WCJ found subject matter jurisdiction over the claimed injury pursuant to section 3600.5(a) when the Rams entered an oral contract with applicant in California. (Finding of Fact No. 4.) The WCJ's Report observes:
The facts that decided it
What the panel treated as outcome-determinative, and which side it favoured.
Applicant entered into oral contracts of hire with the St. Louis Rams and Seattle Seahawks while in California.
Favours Applicant prevailed
This established a California contract of hire, conferring subject matter jurisdiction under Labor Code section 3600.5(a).
From the decision · page 7At the time of trial, the applicant testified that he agreed to play for the St. Louis Rams and the Seattle Seahawks while he was in California.1
The rules the panel named
Authorities as the decision cited them, with how this panel applied each one.
Labor Code section 3600.5
Labor Code section 3600.5(a) confers jurisdiction where there is a California contract of hire.
The panel adopted the WCJ's finding that the applicant's oral contracts of hire in California confer jurisdiction, overriding exemptions in subsections (c) and (d).
From the decision · page 1In addition to the WCJ's well-reasoned Report, we observe the following. Defendant St. Louis Rams contend the court lacks jurisdiction over the defendant pursuant to Labor Code1 section 3600.5(c) because applicant had less than 20 percent of his duty days with the Rams. (Rams' Petition, dated January 19, 2023, at p. 6:11.) However, the WCJ found subject matter jurisdiction over the claimed injury pursuant to section 3600.5(a) when the Rams entered an oral contract with applicant in California. (Finding of Fact No. 4.) The WCJ's Report observes:
Bowen v. Workers' Comp. Appeals Bd. (1999) 73 Cal. App. 4th 15
A contract of hire in California supports jurisdiction even if injury occurred out-of-state (Bowen).
The panel cited Bowen to affirm that a California contract of hire supports jurisdiction over claims based on out-of-state injury.
From the decision · page 2As is relevant here, the Legislature stated: "It is the intent of the Legislature that the changes made to law by this act shall have no impact or alter in any way the decision of the court in [Bowen v. Workers' Comp. Appeals Bd.] (1999) 73 Cal. App. 4th 15 [86 Cal. Rptr. 2d 95]." (Stats. 2013 ch. 653 (AB 1309) § 3.) The central holding of Bowen, affirming sections 3600.5(a) and 5305, is that a contract of hire in this state will support the exercise of California jurisdiction even over a claim based purely on out-of-state injury, and that a player's signing of the contract while in this state constitutes hire in this state for that purpose. (Bowen, supra, 73 Cal. App. 4th at 27.)
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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.
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