Chuck Tiffany — ADJ8402781

Chuck Tiffany, a professional baseball player, claimed cumulative trauma injuries to multiple body parts during employment with several teams from 2003 to 2010. The WCJ found AOE/COE injury to the left hip, left shoulder, left elbow, and knees and determined the section 5412 date of injury occurred after applicant's career ended, placing the section 5500.5 liability period in the last year of injurious exposure (August 29, 2009 – August 28, 2010) with the Golden Baseball League/State Fund. Defendant Golden Baseball League/State Fund sought reconsideration, arguing the date of injury was prior to July 2006 (when applicant had rotator cuff surgery) or that there were two separate cumulative injuries. The Board found the record lacked substantial evidence on when applicant first suffered compensable disability and when he knew or should have known it was work-related. The Board affirmed the F&A in part but deferred the section 5412 date of injury and section 5500.5 liability period issues, rescinded the award, and remanded for development of the record.