Lincoln, Michael

Professional baseball pitcher Michael Lincoln alleged cumulative trauma injuries during multiple employment periods with several MLB teams. The WCJ found two separate cumulative trauma injuries (1999-2004 with the Cardinals/Pirates, and 2008-2010 with the Reds), awarded permanent and temporary disability, found California jurisdiction, and rejected statute of limitations defenses. On reconsideration in June 2024, the Board affirmed but amended the Labor Code section 5412 date of injury for ADJ15700993 to November 2, 2016. Travelers and Ace then filed successive petitions for reconsideration, which the Board denied on September 16, 2024, finding Travelers' challenge to the injurious exposure end date was an improper successive petition and rejecting both defendants' arguments that the 5412 date of injury should be 2004. The Board reasoned that the date of injury for cumulative trauma occurs when the cumulative effect ripens into permanent disability and the worker knows it is work-related, which was not shown before November 2, 2016.