Sameer Sood — ADJ19756417

Applicant Sameer Sood, a police lieutenant for the permissibly self-insured City of Sacramento, claimed a right knee injury sustained on August 10, 2024 while sparring during an open mat session at Granite Bay Jiu Jitsu. The sole trial issue was whether the off-duty activity injury was barred by Labor Code section 3600(a)(9), which excludes voluntary recreational/athletic activities unless they are a reasonable expectancy of employment. The WCJ found the injury compensable, reasoning that although lieutenants had no formal CPT or physical fitness mandate, they were required to maintain POST certification and were 'highly recommended' to stay fit, making it objectively reasonable that applicant believed jiu-jitsu training was expected. The Board adopted the WCJ's section 3600(a)(9) analysis but noted the record lacked substantial medical evidence to support the injury finding. The Board granted reconsideration, rescinded the Findings, and substituted a new Findings holding the claim is not barred by section 3600(a)(9) while deferring all other issues (including medical proof of injury).