Keiaho, Freddy

Professional athlete Freddy Keiaho claimed a cumulative injury (April 15, 2005 to December 1, 2010) to numerous body parts while employed by the Indianapolis Colts and Jacksonville Jaguars. A WCAB panel found subject matter jurisdiction because applicant was hired in California. Both defendants sought reconsideration: the Colts argued applicant failed to prove the physical location of his contract advisor when accepting offers, and the Jaguars argued the written contract signed in Florida (with an integration clause) was the only operative agreement under Tripplett. The Board denied both petitions, holding that applicant accepted the Colts' offers while physically in California (the contract advisor's location being non-dispositive because the advisor could not bind applicant), and that a subsequently signed written contract cannot divest the WCAB of statutorily conferred jurisdiction. Three separate California hirings—two by the Colts and one by the Jaguars—each independently conferred jurisdiction over the entire cumulative injury under section 5305.