Matthews v. National Football League Management Council

Plaintiff-Appellant Bruce Matthews played professional football for 19 years. When he retired in 2002, he was employed by the Tennessee Titans. In 2008, he filed a workers’ compensation claim in California, alleging that he suffered pain and disability from injuries incurred during his career as a professional football player.

Matthews asks us to vacate an arbitration award that prohibits him from pursuing workers’ compensation benefits under California law. He contends that the award violates California public policy barring contractual waiver of workers’ compensation benefits and federal labor policy providing that an employment agreement may not preempt state minimum labor standards. Matthews also argues that the award is in manifest disregard of the Full Faith and Credit Clause of the United States Constitution.

We hold that Matthews has not alleged sufficient contacts with California to show that his workers’ compensation claim comes within the scope of California’s workers’ compensation regime. He has therefore not met his burden of establishing that the arbitration award prohibiting him from pursuing California benefits violates an explicit, well-defined and…