Manderino, Chris

Professional football player Chris Manderino sought reconsideration of an August 7, 2023 Findings and Order in which the WCJ found California lacked personal jurisdiction over the Cincinnati Bengals and Kansas City Chiefs and that applicant's contracts contained valid choice of law/forum clauses. Applicant argued both defendants waived the personal jurisdiction defense by making general appearances and that he entered contracts of hire while within California's territorial jurisdiction. The WCJ found applicant not credible regarding contract formation and that he had no work activities in California. The Appeals Board granted reconsideration, finding that additional analysis of contract formation factors, personal jurisdiction factors, and potential waiver by general appearance was needed for a just and reasoned decision. The Board deferred issuance of a final decision pending further review of the merits and the entire record.