Robert Jenks — ADJ13797705

Robert Jenks, a professional baseball player, filed a cumulative injury claim against several MLB teams including the Los Angeles Angels. The WCJ found in the May 26, 2022 Findings and Order that the WCAB lacked subject matter jurisdiction because Jenks was not hired in California, did not regularly work here, and California had no legitimate interest in his cumulative injury claim. The Board granted reconsideration to study the issues, and subsequently the Court of Appeal issued Atlanta Falcons v. WCAB (Gandy) (2025), which interpreted Labor Code section 3600.5 and the meaning of 'hire' in California, holding that a California-based team's location ordinarily supplies the necessary connection to deem a contract a California contract for hire. Because the Angels are a California-based team and the WCJ's no-jurisdiction finding rested on a lack of evidence about where the contract was signed, the Board found Gandy directly relevant. The Board issued an order allowing further briefing on Gandy's impact rather than reaching a final decision.