WCPanelIQ
PanelGranted

Sanchez, Jonathan

JONATHAN SANCHEZ, Applicant vs. SAN FRANCISCO GIANTS, et al.; ACE AMERICAN INSURANCE COMPANY, administered by SEDGWICK, Defendants

ADJ number
ADJ11434546
Decision date
Jan 27, 2025
District office
Oxnard
WCJ
—
Claim administrator
Sedgwick (administering for ACE American Insurance Company)
Commissioners
ANNE SCHMITZ, DEPUTY COMMISSIONER, KATHERINE A. ZALEWSKI, CHAIR, JOSÉ H. RAZO, COMMISSIONER

Injury / body parts: left elbow, left ankle, left shoulder, chest

LC §3600LC §3600.5LC §3550LC §5300LC §5301LC §5401LC §5405LC §5500.5

Summary

Jonathan Sanchez, a professional baseball player, claimed a cumulative trauma injury to his left elbow, ankle, and shoulder over his career (May 2004–February 2019). The WCJ found California lacked jurisdiction under Labor Code section 3600.5(d)(1) because Sanchez allegedly played seven or more seasons for non-California-based teams, including time with the Mayaguez (Puerto Rico) and Saltillo (Mexico) clubs. On reconsideration, the WCAB rescinded the F&O, holding the Board has subject matter jurisdiction because Sanchez's eight seasons with the San Francisco Giants and a partial season with the Los Angeles Dodgers established a sufficient connection to California. The Board found that the Mayaguez 'winter league' play was not employment at a minor or major league level under section 3600.5(g)(1), so those four years were not 'seasons' for non-California-based teams, meaning Sanchez played fewer than seven such seasons and qualified for the exception in section 3600.5(d)(1). All other issues were deferred.

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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