Madden III, Curtis

Curtis Madden III, a professional athlete, claimed industrial injury while employed by the permissibly self-insured Seattle Seahawks from 2016 to 2019. Defendant sought reconsideration of a WCJ's finding that California has subject matter jurisdiction over the claim, arguing the NFL-NFLPA collective bargaining agreement (CBA), governed by the Labor Management Relations Act (LMRA), precluded the WCAB from determining when a player is 'hired.' The WCAB affirmed the WCJ's jurisdictional findings, holding that applicant accepted a verbal offer of employment while in California (in Agoura Hills), which constituted a California hiring under Labor Code sections 3600.5(a) and 5305. The Board concluded the claim could be resolved without interpreting the CBA and therefore was not preempted under section 301 of the LMRA. The Board amended Finding of Fact No. 1 to reflect that applicant 'claims' injury (rather than 'sustained' injury) since AOE/COE remains a pending issue, and conformed the body parts to those pleaded at trial.