Averell Spicer — ADJ20181505

Averell Spicer, a professional athlete who played for the Chicago Bears from May 2, 2010 through August 10, 2010, filed a cumulative trauma claim to multiple body parts. After a trial limited to the issue of personal jurisdiction over the Bears, the WCJ issued an F&O dismissing the Bears as a party defendant, finding no personal jurisdiction in California because applicant's injuries occurred at a training camp in Illinois. Applicant petitioned for reconsideration, arguing he signed his contract in California and that the WCJ improperly focused on the connection between the injuries and California rather than the Bears' activities in the state. The Appeals Board granted reconsideration, expressing concern that the WCJ failed to clearly find whether applicant was hired in California (or where he was located when the Bears offered employment). The Board deferred issuance of a final decision pending further review of the record and applicable law.