Castroll, Jacob

Jacob Castroll, a Level III volunteer reserve part-time sworn deputy with the County of Los Angeles Sheriff's Department (paid $1 per year), died on August 11, 2017 while participating in the World Police & Fire Games near Castaic Lake. The WCJ found that decedent was an employee (not barred by section 3352(a)(3)) but that his death did not arise out of and in the course of employment because it stemmed from voluntary off-duty athletic activity barred by section 3600(a)(9). Applicant (decedent's widow) sought reconsideration, arguing decedent subjectively and reasonably believed participation was expected by the employer under the Ezzy reasonable-expectancy test. The Appeals Board granted reconsideration, agreeing decedent was an employee but finding the record insufficient to determine whether the section 3600(a)(9) athletic-activity exclusion applied, noting missing evidence including the personnel file, training records, and guidelines. The Board deferred a final decision pending further review and potential development of the record.