ADJ20181505 — California WCAB decision

What the panel ordered

Petition for reconsideration granted; final decision deferred pending further review of merits and entire record

Petition for reconsideration of WCJ Findings of Fact & Order dismissed Chicago Bears for lack of personal jurisdiction; WCJ recommended denial of petition; WCAB granted reconsideration and deferred final decision pending further review

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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.

Jurisdiction / venueRemanded

The WCJ did not clearly find whether applicant was hired in California or where the Bears reached out to him, which is necessary to evaluate personal jurisdiction; further proceedings are needed to determine this factual question.

From the decision · page 4Here, we are concerned that the WCJ did not clearly make a finding as to whether applicant was hired in California or, perhaps more precisely, where applicant was located at the time the Bears reached out to him to offer him employment. As a result, further study of the record and the caselaw surrounding personal jurisdiction is necessary to determine whether the WCJ's decision can be effectively evaluated in the absence of such a finding, or whether we must return the matter to the WCJ for further proceedings to determine that factual question prior to rendering a judgement on whether there is personal jurisdiction over the Bears in California for purposes of this claim.

The rules the panel named

Authorities as the decision cited them, with how this panel applied each one.

Martin v. Detroit Lions, Inc. (1973) 32 Cal.App.3d 472, 475; International Shoe Co. v. State of Washington (1945) 326 U.S. 310; Michigan Nat. Bank v. Superior Court (1972) 23 Cal.App.3d 1, 6; Code Civ. Proc., § 410.10

A California court may exercise jurisdiction over a nonresident defendant only within the perimeters of the due process clause as delineated by the decisions of the United States Supreme Court.

Due process requires minimum contacts with the state so that maintenance of an action does not offend traditional notions of fair play and substantial justice.

From the decision · page 3(Ibid.) The instant Petition for Reconsideration followed. A California court may exercise jurisdiction over a nonresident defendant only within the perimeters of the due process clause as delineated by the decisions of the United States Supreme Court. (Martin v. Detroit Lions, Inc. (1973) 32 Cal.App.3d 472, 475, citing International Shoe Co. v. State of Washington (1945) 326 U.S. 310 and Michigan Nat. Bank v. Superior Court (1972) 23 Cal.App.3d 1, 6; Code Civ. Proc., § 410.10.) Due process requires that a defendant have certain minimum contacts with a state so that the maintenance of an action in the state does not offend traditional notions of fair play and substantial justice. (McKinley v. Arizona Cardinals (2013) 78 Cal.Comp.Cases 23, 26; Buckner v. Industrial Acci. Com. (1964) 226 Cal.App.2d 619, 623).) "[S]pecific jurisdiction is confined to adjudication of issues deriving from, or connected with, the very controversy that establishes jurisdiction." (Bristol-Myers Squibb Co. v. Superior

Bristol-Myers Squibb Co. v. Superior Court (2017) 582 U.S. 255, 262

Specific jurisdiction is confined to adjudication of issues deriving from, or connected with, the very controversy that establishes jurisdiction.

There must be an affiliation between the forum and the underlying controversy, principally an activity or occurrence that takes place in the forum state and is subject to the state's regulation.

From the decision · page 3(Ibid.) The instant Petition for Reconsideration followed. A California court may exercise jurisdiction over a nonresident defendant only within the perimeters of the due process clause as delineated by the decisions of the United States Supreme Court. (Martin v. Detroit Lions, Inc. (1973) 32 Cal.App.3d 472, 475, citing International Shoe Co. v. State of Washington (1945) 326 U.S. 310 and Michigan Nat. Bank v. Superior Court (1972) 23 Cal.App.3d 1, 6; Code Civ. Proc., § 410.10.) Due process requires that a defendant have certain minimum contacts with a state so that the maintenance of an action in the state does not offend traditional notions of fair play and substantial justice. (McKinley v. Arizona Cardinals (2013) 78 Cal.Comp.Cases 23, 26; Buckner v. Industrial Acci. Com. (1964) 226 Cal.App.2d 619, 623).) "[S]pecific jurisdiction is confined to adjudication of issues deriving from, or connected with, the very controversy that establishes jurisdiction." (Bristol-Myers Squibb Co. v. Superior

ADJ20181505 · May 4, 2026

What the panel ordered

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