Matthew Konan — ADJ10729883

Applicant Matthew Konan, a professional hockey player, claimed cumulative trauma injuries to multiple body parts while playing for the Philadelphia Flyers (2012-2015) and the Tulsa Oilers/ECHL (2015-2016). He never played or practiced in California, but argued that California had jurisdiction under Labor Code sections 3600.5(a) and 5305 because his California-based agent, Eustace King, negotiated and accepted his contracts from his Los Angeles office. The WCJ found no California jurisdiction because applicant signed both contracts outside California (Alberta, Canada for the Flyers; Tulsa, Oklahoma for the Oilers), the Standard Player-Agent Contract expressly prohibited the agent from binding the player without prior written consent, and the contracts contained integration clauses making them effective only upon execution. The WCAB majority adopted and incorporated the WCJ's Report and affirmed the Findings and Order, relying heavily on Tripplett v. WCAB. Commissioner Razo dissented, arguing the agent had operational authority to bind applicant in California, distinguishing Tripplett because the agent was undisputedly in California during negotiations and acceptance.