WCPanelIQ
PanelDenied

Nathan Ruhl — ADJ10622392

NATHAN RUHL, Applicant vs. KANSAS CITY T-BONES, BERKLEYNET MANASSAS; NEWARK BEARS, TRAVELERS INSURANCE/LIBERTY MUTUAL; LAS VEGAS 51’S, JACKSONVILLE, for the LOS ANGELES DODGERS; ACE AMERICAN, adjusted by SEDGWICK CLAIMS MANAGEMENT SERVICES – RIVERSIDE; CHATTANOOGA for the CINCINNATI REDS, self-insured; BAKERSFIELD BLAZE; ST. PETERSBURG, CHARLESTON, PRINCETON and GULF COAST LEAGUE for the ORLANDO RAYS; Defendants

ADJ number
ADJ10622392
Decision date
Dec 29, 2022
District office
Santa Ana
WCJ
—
Claim administrator
Sedgwick Claims Management Services; Gallagher Bassett; Travelers Insurance/Liberty Mutual
Commissioners
JOSÉ H. RAZO, COMMISSIONER, KATHERINE A. ZALEWSKI, CHAIR, MARGUERITE SWEENEY, COMMISSIONER

Injury / body parts: multiple body parts (cumulative trauma)

LC §3600LC §3600.5LC §5300LC §5301LC §5305LC §5500.5LC §3351LC §3357

Summary

Nathan Ruhl, a professional baseball player, asserted a cumulative trauma injury from 1996 to 2005 and sought to establish California WCAB jurisdiction over his claim. The WCJ found his claim exempt under Labor Code section 3600.5(d)(1)(B) because he worked seven or more seasons for teams based outside California. The Board granted reconsideration and addressed three key disputes: how to characterize time under contract to the California-based Dodgers while playing for out-of-state affiliates, whether independent out-of-state teams (Bears/T-Bones) count toward the seven-season limit, and whether an uncompensated injury season (1997) counts. The Board held that time is measured by the player's contracting employer (so Dodgers time counted as California work and Devil Rays time as out-of-state work), that all out-of-state seasons count regardless of California ties, and that the uncompensated 1997 season counts. Calculating 8.2 seasons for out-of-state teams, the Board affirmed that applicant exceeded the seven-season limit and his claim was barred from California jurisdiction.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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