Madden, Curtis, III

Curtis Madden III, a professional football player, claimed industrial injury to multiple body parts while employed by the Seattle Seahawks (permissibly self-insured) from 2016 to 2019. The WCJ found California had subject matter jurisdiction under Labor Code sections 3600.5(a) and 5305, reasoning that applicant accepted a verbal employment offer while at a draft party in Agoura Hills, California, before flying to Seattle to execute a written contract. Defendant petitioned for reconsideration, arguing the WCAB lacks jurisdiction to interpret the NFL-NFLPA collective bargaining agreement (CBA) and to determine the validity of a contract of hire, claiming these issues are preempted by federal law under the Labor Management Relations Act (LMRA). The Appeals Board granted reconsideration to allow further review of the merits and possible development of the record, deferring a final decision. The central issue identified is whether applicant's claim for California workers' compensation can be evaluated without interpreting the CBA.