Marcus Robinson — ADJ9146501

Marcus Robinson, a professional football player, claimed a cumulative trauma injury to multiple body parts during his employment with the Chicago Bears, Baltimore Ravens, and Minnesota Vikings from 1997-2006. He never signed a contract in California, was never a California resident, and played only about four games in California (plus practiced for a fifth game he was deactivated from) out of approximately 146 games across his career—roughly 3% of his exposure. The WCJ found the claim could not be heard in California for lack of sufficient connection to the state under Federal Insurance Co. v. WCAB (Johnson). The Appeals Board, after reconsideration, affirmed the WCJ's substantive determination that California cannot exercise authority over the claim, but amended the finding to clarify that the issue is one of due process rather than the absence of statutory subject-matter jurisdiction. The Board concluded that applicant's own testimony showed his California work was essentially the same as work elsewhere, so the injury was not particularly traceable to California exposure.