The Atlanta Falcons have won a legal battle regarding a workers’ compensation claim filed by former NFL player Wayne Gandy. The Fourth Appellate District, Division Three, of the California Court of Appeal ruled that the Falcons are exempt from liability in Gandy’s claim for a cumulative injury.
Key Players and Timeline
Gandy, who played in the NFL from 1994 to 2009, filed a workers’ compensation claim in California in September 2015, six years after his retirement. He alleged a cumulative injury to multiple body parts sustained during his career. He played for the Los Angeles Rams (LA Rams), St. Louis Rams (STL Rams), Pittsburgh Steelers (Steelers), New Orleans Saints (Saints), and the Atlanta Falcons (Falcons).
Gandy’s claim initially named the LA Rams and STL Rams, later adding the Steelers, Saints, and Falcons. The Workers’ Compensation Judge (WCJ) initially ruled in favor of the Falcons, stating they were exempt from liability under California law. However, the Workers’ Compensation Appeals Board (WCAB) overturned this decision, asserting jurisdiction over the claim. The Falcons then appealed this decision.
The Court’s Decision
The Court of Appeal sided with the Falcons, annulling the WCAB’s decision. The court’s main focus was on interpreting California Labor Code section 3600.5, specifically subdivisions (c) and (d), which deal with workers’ compensation claims from professional athletes.
Understanding the Law
California’s workers’ compensation system generally covers employees who have contracts in California or work regularly in the state, even if the injury happens outside of California. However, there are exceptions. Section 3600.5(c) and (d) of the Labor Code, added in 2013, specifically address cumulative injury claims by professional athletes.
Section 3600.5(c) states that athletes hired outside of California are exempt if their employer provides workers’ compensation coverage in another state, and the athlete spends less than 20% of their duty days in California.
Section 3600.5(d) clarifies the situation when an athlete has worked for both California and non-California teams. In this case, the athlete is exempt if all their employers in their last year of work are exempt, unless the athlete meets either of two conditions:
* They worked for two or more seasons for a California-based team or worked 20% or more of their duty days in California or for a California-based team.
* They worked for fewer than seven seasons for any non-California team.
The Court’s Reasoning
The court determined that Gandy and the Falcons fell under the exemptions provided by sections 3600.5(c) and (d). The court found that Gandy’s last day of work for the Falcons in California was November 30, 2008. In the 365 days leading up to that date, he played in four games and had at least 250 practice days. Less than 20% of his duty days were in California.
Furthermore, Gandy did not meet the conditions outlined in section 3600.5(d). He had only one season with a California-based team (the LA Rams), and he did not work 20% or more of his career duty days in California or for a California-based team. He played for 15 seasons and did not meet the criteria to overcome the exemption.
The court also took issue with the WCAB’s interpretation of the law. The WCAB argued that the exemptions in sections 3600.5(c) and (d) did not apply to athletes who had signed a contract with a California team, regardless of where the injury occurred or where the athlete played for the majority of their career. The Court of Appeal rejected this interpretation, stating it would render section 3600.5(d) meaningless. The court emphasized that the Legislature’s intent was to limit California workers’ compensation benefits for professional athletes with cumulative injuries, especially those employed by out-of-state teams.
Impact of the Ruling
The Court of Appeal’s decision means the Falcons are not liable for Gandy’s workers’ compensation claim. The court remanded the matter for further proceedings consistent with its opinion. The court’s decision also renders moot the other issues tried before the WCJ, including the choice of law/forum selection provisions in Gandy’s contract with the Falcons, and whether Gandy’s claim is time-barred.