ADJ18852673 — California WCAB decision

What the panel ordered

Petition for Reconsideration granted; final decision deferred pending further review of merits

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 / venueApplicant prevailedhead

The Appeals Board granted reconsideration to further study whether meeting the elements in Labor Code section 3600.5(d)(1)(A) and (B) alone is sufficient to establish subject matter jurisdiction in California, deferring final decision pending further review.

From the decision · page 2The issue submitted for decision was: Does California have subject matter jurisdiction over applicant's claim of cumulative traumatic injury?

The facts that decided it

What the panel treated as outcome-determinative, and which side it favoured.

Applicant did not play regularly, temporarily or otherwise within California during the claimed cumulative traumatic injury period.

The rules the panel named

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

Labor Code

Labor Code section 3600.5(d)

Applied to determine subject matter jurisdiction for professional athlete's cumulative trauma injury claim.

Labor Code

Labor Code section 3600.5(a)

Referenced regarding jurisdiction over injuries outside California.

From the decision · page 4In addition to injuries occurring in California, the WCAB can also assert subject matter jurisdiction over injuries occurring outside this state in certain circumstances. Section 3600.5(a) states: "If an employee who has been hired or is regularly working in the state receives personal injury by accident arising out of and in the course of employment outside of this state, he or she, or his or her dependents, in the case of his or her death, shall be entitled to compensation according to the law of this state." (§ 3600.5(a).) Similarly, section 5305 states: "The Division of Workers' Compensation, including the administrative director, and the appeals board have jurisdiction over all controversies arising out of injuries suffered outside the territorial limits of this state in those

Labor Code

Labor Code section 5305

Referenced regarding jurisdiction over injuries outside California.

From the decision · page 4In addition to injuries occurring in California, the WCAB can also assert subject matter jurisdiction over injuries occurring outside this state in certain circumstances. Section 3600.5(a) states: "If an employee who has been hired or is regularly working in the state receives personal injury by accident arising out of and in the course of employment outside of this state, he or she, or his or her dependents, in the case of his or her death, shall be entitled to compensation according to the law of this state." (§ 3600.5(a).) Similarly, section 5305 states: "The Division of Workers' Compensation, including the administrative director, and the appeals board have jurisdiction over all controversies arising out of injuries suffered outside the territorial limits of this state in those

ADJ18852673 · July 14, 2025

What the panel ordered

What was disputed, and how it came out

The facts that decided it

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The rules the panel named

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