WCPanelIQ
PanelGranted in Part

Bruce Campbell — ADJ13410423

BRUCE CAMPBELL, Applicant vs. OAKLAND RAIDERS; ACE AMERICAN c/o TRISTAR RISK MANAGEMENT; CAROLINA PANTHERS; GREAT DIVIDE INSURANCE COMPANY c/o BERKLEY ENTERTAINMENT, Defendants

ADJ number
ADJ13410423
Decision date
May 28, 2026
District office
Santa Ana
WCJ
—
Claim administrator
TriStar Risk Management (for ACE American); Berkley Entertainment (for Great Divide Insurance Company)
Commissioners
JOSEPH V. CAPURRO, COMMISSIONER, ANNE SCHMITZ, DEPUTY COMMISSIONER, CRAIG L. SNELLINGS, COMMISSIONER

Injury / body parts: cumulative trauma

LC §5500.5LC §3600.5CCR §10605

Summary

Applicant Bruce Campbell, a professional football player, filed a cumulative trauma injury claim. The WCJ found WCAB had jurisdiction because applicant was hired in California. The Carolina Panthers sought reconsideration, arguing that the second contract with the Oakland Raiders (which the Panthers assumed when applicant was traded) was not entered into in California, so there was no statutory subject matter jurisdiction over them and liability should 'roll back' to the Raiders under Labor Code section 5500.5. After granting reconsideration, the Court of Appeal issued Atlanta Falcons v. WCAB (Gandy), interpreting Labor Code section 3600.5(c) and (d) and what constitutes 'hire' in California. The Board issued an order allowing further briefing so the parties could address Gandy's impact before a final decision on the merits.

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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