Sellner, Scott

Applicant Scott Sellner, a California resident, alleged a cumulative trauma injury from his professional baseball employment with the Cincinnati Reds (permissibly self-insured) during 1987-1991. The Reds, specially appearing, challenged the WCAB's personal jurisdiction, arguing it never purposefully directed activities toward California, that applicant never played games in California, and that the exercise of jurisdiction was unreasonable under the three-part test in AMA Multimedia LLC v. Wanat. The WCJ found personal jurisdiction existed because the Reds used a California scout to recruit applicant, negotiated and signed contracts in California, and arranged applicant's travel from California. The Appeals Board adopted the WCJ's Report and denied reconsideration, holding that the Reds' acts of scouting and recruiting a California athlete who was injured as a result constituted sufficient minimum contacts for specific personal jurisdiction. The Board also addressed timeliness under amended Labor Code section 5909, confirming it acted within 60 days of transmission.