ADJ17606447 — California WCAB decision

What the panel ordered

Petition for Reconsideration granted; final decision after reconsideration deferred pending further review of merits and record.

Applicant seeks reconsideration of the August 14, 2025 Findings and Order where the WCJ found lack of personal jurisdiction over the Philadelphia Phillies and the Fargo-Moorehead Redhawks.

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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 / venueApplicant prevailed

The Board preliminarily found that the WCJ erred in finding lack of personal jurisdiction because the applicant was recruited and signed contracts with both teams in California, establishing sufficient contacts for jurisdiction, warranting reconsideration.

From the decision · page 1Applicant seeks reconsideration of the August 14, 2025 Findings and Order (F&O), wherein the workers' compensation administrative law judge (WCJ) found that applicant, while employed as a professional athlete from June 1, 2006 to October 1, 2015, claims to have sustained industrial injury to his head, neck, back, thighs, bilateral shoulders, bilateral wrists, bilateral hands, bilateral fingers, bilateral legs, bilateral knees, bilateral ankles, bilateral toes, feet, internal, ENT/TMG, neurological, psyche, and sleep. The WCJ found that the court lacked personal jurisdiction over the Philadelphia Phillies and the Fargo-Moorehead Redhawks.

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 so that maintenance of an action does not offend traditional notions of fair play and substantial justice.

Applied to assess personal jurisdiction over nonresident defendants.

From the decision · page 3A 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 [66 S.Ct. 154] 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].)

Bristol-Myers Squibb Company v. Superior Court of the State of California (2017) 137 S. Ct. 1773, 1780

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

Applied to determine the connection between the defendant's forum-related activity and the claim.

From the decision · page 4connected with the defendant's forum-related activity." (Buckeye Boiler Co. v. Superior Court of Los Angeles County (1969) 71 Cal.2d 893, 899 [80 Cal.Rptr. 113].) "[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 Court, supra, 137 S.Ct. 1773, 1780.)

ADJ17606447 · November 10, 2025

What the panel ordered

What was disputed, and how it came out

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The facts that decided it

The rules the panel named

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