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PanelGranted in Part

Gerard Warren — ADJ9318664

GERARD WARREN, Applicant vs. OAKLAND RAIDERS; ACE AMERICAN INSURANCE, administered by TRISTAR RISK MANAGEMENT; ACE AMERICAN INSURANCE, administered by ESIS; NEW ENGLAND PATRIOTS; GREAT DIVIDE INSURANCE COMPANY, administered by BERKLEY ENTERTAINMENT, Defendants

ADJ number: ADJ9318664
Decision date: Apr 27, 2026
District office: Santa Ana
WCJ: —
Claim administrator: TriStar Risk Management (for ACE American Insurance); ESIS (for ACE American Insurance); Berkley Entertainment (for Great Divide Insurance Company)
Commissioners: JOSEPH V. CAPURRO, COMMISSIONER, JOSÉ H. RAZO, COMMISSIONER, ANNE SCHMITZ, DEPUTY COMMISSIONER

LC §3600.5CCR §10605

Summary

Professional football player Gerard Warren filed a California workers' compensation claim based on his regular employment with the Oakland Raiders during the injurious exposure period, though not during the last year of his career. The WCJ found California jurisdiction existed under Labor Code section 3600.5(a) based on the regular Raiders employment, and that subdivisions (c) and (d) did not apply. The Raiders/ACE American (administered by TriStar) sought reconsideration, arguing subdivisions (c) and (d) apply to all claims filed after their effective date regardless of regular California employment. After reconsideration was granted, the Court of Appeal issued Atlanta Falcons v. WCAB (Gandy) (2025) interpreting section 3600.5(c) and (d), which the Board found directly relevant. The Board ordered further briefing on the impact of Gandy before rendering a final 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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Similar decisions

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