Atlanta Falcons v. Workers' Comp. Appeals Bd.

FACTS

In September 2015, Gandy filed a claim for workers’ compensation with the State of California, asserting he suffered a cumulative injury during his 15 seasons with the NFL. He initially named the LA Rams and the STL Rams as his employers, but later added the Steelers, the Saints, and the Falcons as additional employers. In June 2019, Gandy’s claim went to trial on three issues: (1) whether California has jurisdiction over Gandy’s claim; (2) whether jurisdiction should be exercised in light of the choice of law and forum selection clauses in Gandy’s contracts with the Falcons and the Saints (McKinley v. Arizona Cardinals (2013) 78 Cal.Comp.Cases 23); and (3) whether Gandy’s claim against the Falcons was barred by the applicable statutes of limitation. The following evidence was either stipulated to by the parties or presented at trial. Gandy was employed by the LA Rams from July 1994 to sometime in 1995, the STL Rams from sometime in 1995 to February 1999, the Steelers from April 1999 to February 2003, the Saints from March 2003 to April 2006, and the Falcons from April 2006 to February 2009. The contract Gandy signed with the LA Rams in California covered his employment…