Michele Clark — ADJ18752560, ADJ18752569, ADJ18752577

Applicant Michele Clark, a lifelong Texas resident who worked entirely remotely from Houston for iRhythm Technologies, filed three claims (a cumulative trauma and two specific injuries) alleging injuries to her hands, wrists, arms, shoulder, back, and stress. Defendant contested jurisdiction, and the WCJ found subject matter jurisdiction based on the theory that applicant was hired in California because the employer counter-signed the At-will Employment Agreement in San Francisco. The Board granted reconsideration, finding the WCJ and parties conflated personal and subject matter jurisdiction, and that the only issue actually submitted (personal jurisdiction) was clearly established given defendant's California corporate presence and its contractual consent to California jurisdiction. The Board rescinded the F&O, substituted an order finding personal jurisdiction over defendant, and deferred the issue of subject matter jurisdiction because it was not properly submitted and the record needs further development regarding the location of hire and defendant's California-based status.