Personal jurisdiction over a out-of-state football team not proved and therefore no jurisdiction in California

This is a Board Panel decision

This is a very significant case for workers’ compensation principles.

The applicant was a football player. He claimed injury to his head, neck, shoulder, elbows, bilateral wrists. hands, hips, knees, feet, TMJ, neuro, internal, psyche and sleep while employed by the Cleveland Browns.

The Browns employed the applicant for several weeks before releasing him and paying for his travel back to California. The Browns went to trial and contended there was no personal jurisdiction over them in California.

A Workers’ Compensation Judge (WCJ) ruled that there was not sufficient contacts with California to establish personal jurisdiction over the Browns and dismissed them.

A codefendant petitioned for reconsideration. The Workers’ Compensation Appeals Board (WCAB) in a Board panel decision agreed with the WCJ.

Applicant who resided in California testified that he never spoke to the Browns while in California. His agent, who was in Arizona, did not enter into a contract with the Browns while the applicant was in California. The applicant did not accept the offer of employment until he was in Ohio and had passed a physical examination. Applicant’s employment contract was not formed while he was in California. He never played a game in California.

The WCAB reviewed numerous cases and determined there was not sufficient contacts with California to confer personal jurisdiction. Therefore, the Browns were dismissed.

Lautner v. Baltimore Ravens

 Editor: Harvey Brown
Samuelsen, Gonzalez, Valenzuela & Brown
3501 Jamboree Suite 602
Newport Beach, Ca 92660
(949) 689-5586


Harvey Brown
3501 Jamboree Rd. Suite 602
Newport Beach, CA 92660

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