Freddie Mitchell — ADJ7161613

Freddie Mitchell, a former professional football player, sought reconsideration of a July 8, 2021 Findings and Order finding his SIBTF claim barred by the statute of limitations. Mitchell's underlying claim arose from injuries during his employment with the Kansas City Chiefs (2001-2005), resolved by a Compromise and Release approved May 31, 2012; he filed his SIBTF application on May 3, 2019. The WCAB granted reconsideration, finding the existing record deficient because there were no Minutes of Hearing, Summary of Evidence, or admitted exhibits, making the basis for the WCJ's decision impossible to ascertain under section 5313 and Hamilton. The Board rescinded the Findings and Order, deferred the limitations issue, and returned the matter to the trial level for further proceedings. The Board also provided guidance on the SIBTF limitations standard under Talcott and its progeny.