Dennis McKinley

Dennis McKinley, a professional football player for the Arizona Cardinals from 1999 to 2003, filed a California cumulative trauma claim alleging injury to multiple body parts incurred during his NFL career. His three employment contracts, made in Arizona, contained an identical mandatory forum selection clause requiring workers' compensation claims to be filed with the Industrial Commission of Arizona under Arizona law. The WCAB, sitting en banc, held that it would decline to exercise jurisdiction over a cumulative injury claim where there is a reasonable mandatory forum selection clause designating another state and only limited connection to California. McKinley's California connection consisted of a five-day training camp in La Jolla and seven games out of 80 played during four years, while he resided in Arizona and performed the substantial majority of his work there. The Board affirmed the WCJ's decision to decline jurisdiction, effectively dismissing the California claim.