Joel Garcia — ADJ13153374, ADJ13153421, ADJ14679364

Professional baseball player Joel Garcia filed workers' compensation claims against the San Diego Padres (insured by ACE American, administered by Sedgwick). In a prior Decision After Reconsideration, the WCAB found it had subject-matter jurisdiction because applicant was hired in California under the newly decided Court of Appeal case Atlanta Falcons v. WCAB (Gandy) (2025), which held that hire by a California-based team constitutes hire in California even if the offer was accepted elsewhere. The Padres sought reconsideration, arguing the Gandy statement was dicta and that the court should have applied prior precedent (like Tripplett) focused on where the offeree accepted the offer. The Board denied reconsideration, holding that Gandy's equation of hire by a California-based team with hire in California is central to its holding and binding precedent, not dicta. The Board found the Padres' arguments—including misleading characterizations of a prior panel decision (Danzey)—unpersuasive and noted that any disagreement with Gandy must be addressed to a higher court.