Brock Peterson — ADJ19384154, ADJ20829009

Brock Peterson, a professional baseball player, filed a cumulative trauma claim covering injuries sustained from January 7, 2010 through September 15, 2015 while working for multiple teams. The WCJ found personal jurisdiction over the Los Angeles Dodgers and held that Labor Code section 3600.5(c) and (d) did not bar applicant's claim because the Dodgers, a California-based employer, employed applicant during the last year of his career. The Dodgers petitioned for reconsideration, arguing they did not hire applicant in California and meet the exemption requirements under section 3600.5(c). The Appeals Board granted reconsideration, expressing concern over a possible lack of substantial evidence regarding whether and how applicant was hired by the Dodgers (he was traded by the Nationals) and whether he performed any work for the Dodgers in California during his last year. The Board deferred a final decision pending further review of the entire record in light of Atlanta Falcons v. WCAB (Gandy).