WCPanelIQ
PanelGranted in Part

Joel Garcia — ADJ13153374, ADJ13153421, ADJ14679364

JOEL GARCIA, Applicant vs. SAN DIEGO PADRES; ACE AMERICAN INSURANCE, administered by SEDGWICK, Defendants

ADJ number
ADJ13153374, ADJ13153421, ADJ14679364
Decision date
Apr 16, 2026
District office
Santa Ana
WCJ
—
Claim administrator
Sedgwick (administering for ACE American Insurance)
Commissioners
ANNE SCHMITZ, DEPUTY COMMISSIONER, KATHERINE A. ZALEWSKI, CHAIR, JOSÉ H. RAZO, COMMISSIONER
LC §3600.5CCR §10605

Summary

Applicant Joel Garcia, employed by the San Diego Padres, sought reconsideration of a May 12, 2021 Joint Findings of Fact in which the WCJ found no California jurisdiction over his specific and cumulative injury claims, concluding he was neither hired nor regularly employed in California. The Appeals Board had previously granted reconsideration on August 2, 2021. After the grant, the Court of Appeal issued Atlanta Falcons v. WCAB (Gandy) (2025), which interpreted Labor Code section 3600.5(c) and (d) and the meaning of 'hire' in California, reasoning that a California-based team's location supplies the necessary connection to deem a contract a California contract for hire. Because it is undisputed Garcia was hired by a California-based team, the Board found Gandy directly relevant and ordered further briefing on its impact. The Board issued an Order Allowing Further Briefing rather than a final merits decision.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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