WCPanelIQ
PanelGranted

Hatchette, Matthew

MATTHEW HATCHETTE, Applicant vs. OAKLAND RAIDERS; TIG/FAIRMONT PREMIER INSURANCE COMPANY, administered by ZENITH INSURANCE COMPANY; JACKSONVILLE JAGUARS; ACE AMERICAN INSURANCE COMPANY, administered by QUAL-LYNX; NEW YORK JETS; USF&G, administered by GALLAGHER BASSETT SERVICES, INC.; OAKLAND RAIDERS; CHUBB, PACIFIC EMPLOYERS INSURANCE, administered by SEDGWICK CMS, Defendants

ADJ number
ADJ11706407
Decision date
Apr 14, 2025
District office
Santa Ana
WCJ
—
Claim administrator
Qual-Lynx (administrator for ACE American Insurance Company/Chubb for Jacksonville Jaguars); Zenith Insurance Company (for TIG/Fairmont Premier, Oakland Raiders); Gallagher Bassett Services, Inc. (for USF&G, New York Jets); Sedgwick CMS (for Chubb/Pacific Employers, Oakland Raiders)
Commissioners
KATHERINE A. ZALEWSKI, CHAIR, JOSEPH V. CAPURRO, COMMISSIONER, PAUL KELLY, COMMISSIONER

Injury / body parts: head, neck, back, hips, arms, legs, knees, ankles, feet, toes, elbows, wrists, hands, fingers, left shoulder, digestive, excretory, circulatory, internal, chronic pain, ENT/TMJ, hearing, neurological, psyche/stress, vision, sleep, reproductive, neuropsych

LC §5909LC §5900LC §5950LC §5901LC §5907LC §5908LC §5908.5LC §5803

Summary

Matthew Hatchette, a former professional football player, filed a 2018 cumulative trauma claim (April 1997-August 2004) against multiple NFL teams including the Jacksonville Jaguars, Oakland Raiders, and New York Jets, asserting California jurisdiction. After trial, the WCJ found California had subject matter and personal jurisdiction over the Jaguars, that the Jaguars had waived personal jurisdiction, and that the August 18, 2008 Order dismissing the Jaguars and the related Compromise and Release were not judgments on the merits, so res judicata did not bar the claim. The Jaguars petitioned for reconsideration, arguing the 2008 dismissal order was a final order barring relitigation by res judicata and that proceeding violated due process. The WCAB granted reconsideration to allow further study of whether claim preclusion or issue preclusion applies, finding the record unclear on these points. The Board deferred a final decision on the merits pending further review of the entire record.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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