Felix Rodriguez — ADJ9477566

Felix Rodriguez, a professional baseball player, filed a cumulative injury claim against the Los Angeles Dodgers and numerous other teams. The WCJ found in an August 14, 2019 Findings & Order that Labor Code section 3600.5, subdivisions (c) and (d) did not bar the claim because defendants failed to prove the necessary factual predicates. Several out-of-state defendant teams (Yankees, Phillies, Giants, Reds) sought reconsideration, arguing applicant's last employer was exempt under subdivision (d) and that his more than seven years of work for non-California teams barred his entire claim under the safe harbor clause. After granting reconsideration, the Court of Appeal issued Atlanta Falcons v. WCAB (Gandy) (2025), interpreting section 3600.5(c) and (d) and the meaning of 'hire' in California. The Appeals Board ordered further briefing on Gandy's impact and two additional points before rendering a final decision.