ADJ14657802 — California WCAB decision

What the panel ordered

Petition for Reconsideration granted; Findings and Order affirmed as amended to reflect no California jurisdiction over Cleveland Browns/Baltimore Ravens

Petition for Reconsideration granted to clarify lack of California jurisdiction over Cleveland Browns/Baltimore Ravens; Findings and Order of July 1, 2022 affirmed as amended

Read the official decision →

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 / venueDefendant prevailed

The record did not support the formation of a contract of hire in California or sufficient minimum contacts for personal jurisdiction over the Cleveland Browns/Baltimore Ravens. Applicant did not play games, travel to, or sustain injury in California while employed by the Browns. The Browns' California games occurred after applicant's release.

The facts that decided it

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

Applicant did not play games, travel to, or sustain injury in California while employed by the Cleveland Browns

Favours Defendant prevailed

This lack of contact meant no basis for personal jurisdiction over the Browns in California

The rules the panel named

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

International Shoe Co. v. State of Washington, 326 U.S. 310

Due process requires minimum contacts with the forum state for personal jurisdiction to be valid

Applied to determine lack of personal jurisdiction over Cleveland Browns

From the decision · page 4A 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 [1973 Cal.App. LEXIS 991], citing International Shoe Co. v. State of Washington, 326 U.S. 310 [90 L.Ed. 95, 66 S.Ct. 154, 161 A.L.R. 1057] and Michigan Nat. Bank v. Superior Court, 23 Cal.App.3d 1, 6 [99 Cal.Rptr. 823]; 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 [2013 Cal. Wrk. Comp. LEXIS 2]; Buckner v. Industrial Acci. Com. (1964) 226 Cal.App.2d 619, 623) [1964 Cal. App. LEXIS 1319].)

Greener v. Workers' Comp. Appeals Bd. of California (1993) 6 Cal.4th 1028

California courts distinguish between subject matter jurisdiction and personal jurisdiction; subject matter jurisdiction relates to the cause of action, personal jurisdiction to the party's contacts

Applied to clarify jurisdictional distinctions in this case

From the decision · page 4Personal jurisdiction is not determined by the nature of the action, but by the legal existence of the party and either its presence in the state or other conduct permitting the court to exercise jurisdiction over the party. Subject matter jurisdiction, by contrast, is the power of the court over a cause of action or to act in a particular way. (Greener v. Workers' Comp. Appeals Bd. of California (1993) 6 Cal.4th 1028 [58 Cal. Comp. Cases 793, 795].)

ADJ14657802 · September 19, 2022

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

What proof carried it

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