Steve Lauter — ADJ14657802

Applicant Steve Lauter, a former professional football player, claimed cumulative injuries while employed briefly by the San Diego Chargers (May-July 1987) and the Cleveland Browns (now Baltimore Ravens) (September-October 1987). The Cleveland Browns specially appeared to contest California personal jurisdiction. After trial on jurisdiction alone, the WCJ found no personal jurisdiction over the Browns and dismissed them. CIGA petitioned for reconsideration, arguing the Browns had sufficient minimum contacts with California and that an oral contract of hire was formed in California. The WCAB panel granted reconsideration but affirmed the WCJ's finding, amending Finding of Fact No. 2 to clarify there is no California jurisdiction over the Cleveland Browns/Baltimore Ravens, and upheld application of former Labor Code section 4062 (pre-SB899) for the medical-legal procedure.