WCPanelIQ
PanelDenied

Slavin, Tyler

TYLER SLAVIN, Applicant vs. ST. LOUIS RAMS/LOS ANGELES RAMS; GREAT DIVIDE INSURANCE COMPANY, c/o BERKLEY ENTERTAINMENT; FOOTBALL NORTHWEST LLC/SEATTLE SEAHAWKS, permissibly self-insured, administered by CCMSI, Defendants

ADJ number
ADJ12766196
Decision date
Mar 12, 2024
District office
Santa Ana
WCJ
Oliver Cathey
Claim administrator
Berkley Entertainment (for Great Divide Insurance Company); CCMSI (for Football Northwest LLC/Seattle Seahawks)
Commissioners
—

Injury / body parts: head, neck, back, arms, shoulders, elbows, wrists, hands, fingers, legs, hips, knees, ankles, feet, toes, neurological, psychiatric

LC §3600.5LC §5305LC §3203LC §5300LC §5412LC §5500.5

Summary

Tyler Slavin, a professional football player and California resident, filed a cumulative trauma claim (May 8, 2015 through March 9, 2017) against the St. Louis/Los Angeles Rams and the Seattle Seahawks. The WCJ found that Slavin entered oral contracts of hire with both teams while physically located in California (uttering 'Okay, let's do it' to the Rams and 'yes' to the Seahawks practice squad offer over the phone), thereby conferring subject matter jurisdiction under Labor Code sections 3600.5(a) and 5305. The WCJ also found the Seattle Seahawks waived personal jurisdiction by participating in substantive discovery and asserting non-jurisdictional affirmative defenses without filing a motion to quash. The Board adopted the WCJ's report, holding that formation of a California contract of hire obviates the exemption analysis under section 3600.5(c) and (d), and concurred that the Seahawks waived personal jurisdiction. Both defendants' Petitions for Reconsideration were denied.

Issues

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Holding

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