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Keyword: ‘Visiting California for the Workers’ Comp – Part’

California Has No Jurisdiction Over Another Ohio Pro-Sports Case

January 10th, 2014 No comments

Are you tired of pro-sports cases? No? Good!

Today’s post is on the subject of Dan Fike, and, more to the point, his claim against the Baltimore Ravens/Cleveland Browns.  Mr. Fike was a professional football player from June of 1985 to December of 1992.  He sought to have his industrial injuries addressed under California’s workers’ compensation system, alleging a cumulative trauma to the head, neck, back, shoulders, and other body parts.

The defense was one typical of such cases: California did not have jurisdiction.  To support this defense, the Cleveland Browns provided evidence of self-insurance and extra-territorial coverage.  Testimony also established that between 1985 and 1992, applicant played only nine games in California.  Evidence also showed that no contract was entered into in California.

The WCJ found that, despite applicant’s 95.2% permanent disability, California had no jurisdiction under Labor Code section 3600.5.

On reconsideration, applicant argued, among other things, that the WCJ should have focused on the employer’s activities, rather than the employee’s in determining whether the employee was temporarily in the state.  After all, if the employer is regularly active in California, and the employee was just one of many cogs in the state, California should be able to assert jurisdiction over the claim, right?

No.  The answer is no.  Labor Code section 3600.5 is essentially a deal – a trust, a conspiracy between one state and another that says we won’t squeeze your employers for every penny if you won’t squeeze our employers for every penny, within these particular guidelines.   More to the point, even California understands that there are limits to how much your can rob visiting employers before employers stop visiting.

The WCAB denied applicant’s petition, and confirmed that employers from Ohio can safely send their agents into California, without fear of ever needing your humble blogger’s services.  The Court of Appeal denied applicant’s petition for a writ of review.

Now, interestingly enough, we have a statutory limit, aside from Labor Code section 3600.5(b), to such a claim at this point (maybe), and that’s subsection (c).  3600(c) NOW says that if the injured pro-sports athlete was hired outside of California and the employer has insurance outside of California, California does not have jurisdiction if the last year of the athlete’s career had less than 20% “duty days” in the Golden State.

Your humble blogger doesn’t have all the facts for this particular case, but 3600.5(c) is definitely a section worth exploring if you’re defending against a pro-athlete claim.

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Bengals Escape California WC Jurisdiction

June 24th, 2013 No comments

Are you sick and tired of that gloomy intersection where pro-sports and workers’ compensation reluctantly meets?  Well too bad, because there’s more!

Now, I’m not going to bore you with all the details in the recent en banc decision from the Workers’ Compensation Appeals Board, Wesley Carroll v. Cincinnati Bengals.  Here is the skinny on that case: injured pro-sports player Wesley Carroll filed a claim in California after playing some 6 games in California (out of a total of 48; 12.5%).

The Workers’ Compensation Appeals Board found that one of the teams, the Cincinnati Bengals, was exempt from California’s crushing, ruthless, and back-breaking workers’ compensation system thanks to that coveted escape route of Labor Code section 3600.5.

As you may recall, section 3600.5 allows an out-of-state employer to escape California comp jurisdiction if:

  1. The employee is only “temporarily” in California;
  2. The employee is covered by extra-territorial insurance (meaning the policy applies to the worker even when he or she is out of the state in which he or she normally works);
  3. The laws of the state where the employee is normally employed are “similar” to those of California; and
  4. The state where the employee is normally employed has a reciprocity rule with California.  In other words, California keeps its hands off state X, and state X keeps its hands of California employees injured in state X.

Ok, so, why do you care?  After all, it looks like these claims might go the way of the dodo soon enough if certain legislation makes it through the Sacramento maze.  And, even if that fails, there are about 1,700 pro-football players in the United States, some of which are employed in California.  Compare that to almost 16 million people employed in California alone.  Why does this opinion matter to those of us who don’t represent or handle pro sports cases?

I’m glad you asked! (You did ask, right? This slowly unraveling blogger could have sworn he heard a voice ask…)

If we forget about the fact-specific ruling of the Carroll opinion, what is the average person left with?  The WCAB is telling us, in a binding authority opinion, the following:

A person who spent 12.5% of his time in California and the rest employed elsewhere is in the state only temporarily.  As is 15.7% (5 of 32 games played for the Bengals).  In fact, the language of the opinion lends itself to the theory that, even if applicant had spent 99% of his time in California, so long as he had the intent to leave California after his task was completed, he could still be regarded as only temporarily within the state.

Another holding to keep for future need is the WCAB’s opinion with respect to Ohio.  The WCAB here concludes that Ohio recognizes the extraterritorial provisions of other states; and that Ohio exempts California employers and employees from its own workers’ compensation system, thereby satisfying the elements of section 3600.5.

So, if you’ve got an Ohio employee temporarily in the state for a conference, recruiting, training, or a short-term project, you can rely on this opinion to help you raise the 3600.5 defense.  (Note: in a similar case, California jurisdiction was denied based on a forum selection clause.  See: Dennis McKinley v. Arizona Cardinals)

Now here’s something interesting – the WCAB ordered the Bengals dismissed and sent the matter back down to the Workers’ Compensation Judge for further action on this issue.  But what could be left to litigate about?  Well… there’s also the New Orleans Saints.  The opinion doesn’t offer much about the fate of the Saints, but it will be interesting to see the defense the Saints intend to mount (if any).

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Sacramento Moves to Limit Pro-Sports Comp Liability

March 8th, 2013 No comments

The Workers’ Comp thunderstorm in pro-sports paradise continues, as players and teams struggle over whether players can collect workers’ compensation benefits in California after playing one game or attending a training session here.

It looks like the Los Angeles Times has decided to focus its wrath and anger on Assembly Member Henry T. Perea (D – Fresno), for introducing Assembly Bill 1309 which would exempt professional athletes in the fields of baseball, basketball, football, hockey, or soccer if the employee is temporarily in the state if he or she spends less than 90 days in California in the year prior to the date of injury (whether specific or cumulative).

Far be it from your humble blogger to question the wise sages of Sacramento.  After all, he is but the humblest of the humble, both with respects to his blogging and his citizenship.  But, unlike the LA Times, this bill does not go far enough.

I might alter a child’s world by explaining to him that I’m not actually taking his nose, but I think my beloved readers have a firm grasp on the concept that California is not particularly business friendly.

I would submit to you, my readers, that this bill does not go far enough.  Instead of limiting itself to some sports, the bill should be expanded to include all visiting employees, whether here for a 10-day project or a 1-day conference.  Programmers and hospitality service specialists don’t make the headlines the way quarterbacks and goalies do, but how would you like to hire someone in North Dakota and have them attend a 3-day training seminar in California, only to claim a cumulative trauma immediately prior to retirement twenty years later?  And mind you, my dear North Dakota-an (esteemed gentleman or lady from North Dakota), you’ll be paying California dollars on the workers’ comp, not North Dakota dollars.

Right now, the professional sports teams are trying to get this thing passed in Sacramento, and they may or may not succeed.  Imagine if they can’t – imagine if the sports teams are stuck paying out the big bucks for each player looking for a retirement bonus.  At a certain point, wouldn’t it be cheaper to just boycott California games?

As grand as California is, every state is a good state for a training camp, and every state is a good state for a game.  The 49ers will just have to build a new stadium on the other side of the Arizona border, and the Raiders will have to host games on a floating stadium 10 miles out to sea.

Instead of sending our fearless governor to other states to make this state more attractive, perhaps we could start with baby steps – don’t punish non-California employers for visiting California (let alone moving here!)

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Visiting California for the Workers’ Comp – Part 3 of 3

March 8th, 2012 No comments

So by this point, you’ve read Parts 1 and 2 of this article.  You’ve laughed, you’ve cried, and you’ve decided not to give up on doing business in or with California, and also to stop sending your fragile blogger e-mails accusing me of actively trying to depress you.

So what can you, the employer, insurer, or the self-insured employer do to keep your liability down when you send your employees into California?  For starters, either purchase a California workers’ compensation insurance policy or make sure your current policy covers employees when they are out of the state.  Next, ask your attorney to secure a certificate from your state regarding its workers’ compensation reciprocity laws with California.

And what do you do if your state doesn’t have reciprocity or similar laws?  Lobby, and get them passed.  In 2011, Florida adopted House Bill 723, establishing reciprocity laws.  Michigan followed suit later that year with House Bill 5002.  If your state does not have a reciprocity law, perhaps some lobbying dollars spent now can save workers’ compensation dollars in the future.

Kansas has taken another approach.  A recent arbitration ruling in a case between the Kansas City Chiefs and the NFL Players Association held that Chiefs players must bring their workers’ compensation claims in Kansas, ordering the players to abandon their California cases.

The basis of this ruling appears to be the contract terms between the players and the team.  From noted sports-law blogger Daniel J. Friedman, of LockoutLowdown:

“Article 41 of the newly ratified NFL CBA encompasses the NFL and NFLPA’s ‘Worker Compensation’ plan.  As part of this agreement, under Art. 41, Sec. 5 states ‘The parties shall immediately establish a joint committee that will make good faith efforts to negotiate a possible California Workers’ compensation alternative dispute resolution program on a trial basis (i.e., carve out).’  However, Sec. 6 Reservation of Rights states ‘The parties shall retain the positions they held prior to this Agreement with respect to all existing litigation and arbitration involving workers’ compensation issues, including without limitation, the federal and state courses in California (Titans), Illinois (Bears) and New York (Mawae, Harvey) regarding offset issues or choice of law and forum provisions contained in NFL Player Contracts, and nothing in this Article shall affect positions taken in any such pending litigation.’    I do not think that the carve out provision has been agreed to yet but the resolution in this case likely tilts the balance of power back to the League’s favor as they continue to make ‘good faith efforts’ in coming to an agreement related to carve-out.  I would not be surprised if the players in this situation appeal.  However, because this was an arbitration, it will be very difficult to have the ruling overturned unless they can prove their was an abuse of process.”

But, given the fact that California regards contract terms waiving access to California’s workers’ compensation system to be unenforceable, it remains to be seen how effective this approach will prove.

The State of Oregon has put together a list of the reciprocity laws of various states.  You can review it here.  Your humble blogger does gently suggest you verify for yourself any citations found on this website – I certainly have not done so and can not make any claims as to its accuracy or current status.

So, will this fearless blogger, cumulatively traumatized by California’s workers’ compensation system, be seeing you in the Golden State anytime soon?

Visiting California for the Workers’ Comp – Part 2 of 3

March 7th, 2012 2 comments

Yesterday we discussed the problem facing professional sports and California games – players seek California benefits after playing in California a few times as part of a multi-season career.  This is a problem for any business that has prices reflecting non-California workers’ compensation costs.

This problem doesn’t only apply to professional athletes – they just get all the attention.  The same law applies to traveling non-athlete employees.  California hosts conferences.  California hosts training seminars.  California is just a nice place to visit.  And often enough, if you’re looking for skilled talent, California can be a great place to send your agents to do some recruiting.

But while your employees are conferencing, training, visiting, or recruiting, they’re exposing you to liability under California’s workers’ compensation system.  Are you prepared to pay Golden State rates after a lifetime of reasonable prices?  Maybe you don’t have to.

Your hypnotically eloquent blogger may have worked you into a frenzy over the exploitation of employers and insurers nationwide by one-time California visits and the effect of subjecting non-California defendants to California workers’ compensation jurisdiction.

Put down the torches and pitchforks, take apart the guillotine, and please, please, please, stop holding your formerly favorite football star or conference speaker hostage – I assure you there is a better way!

California does jump the gun on claiming jurisdiction as often as possible for workers’ compensation matters, but Labor Code section 3600.5(b) provides a reprieve.  As the law holds, California will not claim jurisdiction over a non-California employee injured in California, even if that injury is part of a cumulative trauma, if the following conditions are met:

  1. The employee is only “temporarily” in California;
  2. The employee is covered by extra-territorial insurance (meaning the policy applies to the worker even when he or she is out of the state in which he or she normally works);
  3. The laws of the state where the employee is normally employed are “similar” to those of California; and
  4. The state where the employee is normally employed has a reciprocity rule with California.  In other words, California keeps its hands off state X, and state X keeps its hands of California employees injured in state X.

In an example contrary to the case mentioned in yesterday’s post, the recent panel opinion in the case of Vaughn Booker v. Cincinnati Bengals held that California did not have jurisdiction over a case in which Vaughn Booker played one game out of 48 in California.

Mr. Booker sought to invoke California’s workers’ compensation system to adjudicate his cumulative trauma claim.  But the Bengals had done their homework, and the WCAB held that (1) applicant only temporarily worked in California; (2) Ohio and California have “similar” workers’ compensation laws; (3) Ohio’s laws cover applicant while he is working in California; and (4)Ohio has reciprocity with California in accordance with section 3600.5(b).

In other words, the Bengals escape to their home territory with their stripes very much intact.

So what can you do other than boycotting the State of California?  Unless you’re willing to give up on medicinal marijuana, body-builder governors, and the nation’s largest concentration of happy cows, I suggest you come back tomorrow for Part 3 of 3.

Visiting California for the Workers’ Comp – Part 1 of 3

March 6th, 2012 2 comments

California workers’ compensation does not often get attention from the world at large.  Most people work, some people get injured, and the lawyers usually fight it out – your typical newspaper or anchor will not discuss workers’ compensation because of its narrow application.  But then, something happens now and again, which shines a flood-light onto the swamp, and sends all of workers’ compensation’s dirty little secrets scurrying for cover.

One such light-bringing event was the front-page story of the Wall Street Journal (this one is behind a pay-wall), which covered, at length, the extent to which small hospitals go to perform expensive and often unnecessary treatments, using an army of lien-representatives to exploit the weakness of California’s workers’ compensation system.  Another is the problem plaguing professional sports.  Your humble blogger had the privilege of summarizing the problem for Lockout Lowdown, a sports law blog, some time ago.

The problem faced by professional sports teams is very real – players will have a lengthy career of several years, play as little as a single game in California, and then file a claim for a career-long cumulative trauma, seeking California benefits.  Often enough, the player’s only contact with California is the one game.  This was the case with Cleveland Crosby, who played between 1980 and 1985, and played a single game in California in 1982.

In Injured Workers’ Insurance Fund of the State of Maryland v. Workers’ Compensation Appeals Board (2001) 66 Cal. Comp. Cases 923 (writ denied), the WCAB held that, because Cleveland Crosby played a game in California while employed by the Baltimore Colts, California had jurisdiction over the Colts for Applicants cumulative trauma injury.

Defendant fought back, naively invoking common sense and reason before bringing out the big guns of Labor Code section 3600.5(b). But Insurance Fund didn’t have the right ammunition: it did not provide certification of reciprocity with California, and the insurance coverage did not appear to cover out-of-state injuries.  Because the defendant in this case failed to prove reciprocity or extra-territorial coverage, applicant prevailed.

But don’t lose hope! Come back tomorrow for Part 2 of 3…

One Day Too Late to File Sports CT Claim!

December 2nd, 2015 No comments

Happy Wednesday, dear readers!

My plan for today’s blog post was to provide you with a list of 10 reasons why, when you have something you need to do, procrastination is not acceptable.  Unfortunately, I kept putting this assignment off, so I didn’t get to it in time for today’s post.

Instead, I bring you the case of Walker v. WCAB.  By way of background, back in 2013, California was in a middle of a mass hysteria of blood-lust for professional athletes.  Basketball players were herded together, only to be tarred and feathered.  Angry mobs descended on hockey players, pouring warm water over ice skating rings to create potholes, and burning copies of the Mighty Ducks.

In response, to pacify the angry hordes taking to the streets, the Legislature offered Assembly Bill 1309, which limited out-of-state professional athlete claims for workers’ compensation.  As part of the language of the bill, it “would provide that these changes apply to all pending claims for benefits filed on or after [Sunday] September 15, 2013, as specified”.

In Walker, it looks like the applicant filed his application on Monday, September 16, 2013.

The parties were in agreement that, if AB1309 applies, the claim is barred, but applicant argued that CCP section 12a and section 10508 (allowing an additional day to perform an act if the last day to act falls on a Saturday, Sunday, or Holiday), means that the claim should not be barred, because, as the law went into effect on a Sunday, all those injured professional athletes should have an extra day to file their claims.

The WCJ agreed, and found the claim is NOT barred.

Well, on appeal, the WCAB reversed, finding that CCP 12a and section 10508 turn on the last day to perform an action.  To the WCAB’s reading, AB1309 did not provide a last day to perform an act, but rather applied additional conditions to filing a claim, such as requiring a minimum amount of time in the State of California prior to filing a pro-sports CT claim.  Accordingly, 12a and 10508 do not apply.  The WCAB ruled the claim is barred.

The COA denied review of the WCAB’s ruling.

Now, your humble blogger is all in favor of claims being denied, but let’s think about this one for a second – AB1309 did not explicitly provide a statute of limitations, BUT it did create conditions which put an expiration date on certain claims.  Given this, isn’t there an implied “last day to perform an act”?  Because the law went into effect on a Sunday, Mr. Walker’s last day to file his application would have been a Saturday, which would have extended his last day to file, as applicant argued to begin with.

Another thought, dear readers — since the world has not ended, and we’re all still here, is it time to consider expanding the effect of AB1309?  Why just professional athletes?  Why only some sports?

What about the guy visiting California to attend a conference in the insurance industry?  What about the lady who is in California temporarily to conduct a job interview of a potential hire from a local law school, only to claim a CT in California for her carpal tunnel syndrome?  Perhaps we need legislation to require a minimum amount of time in California for ANY CT claim.

Perhaps you’d be interested in joining your humble blogger’s fantasy legislation league?

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Social Security Finding of Incapacity Sufficient for Death Benefits

November 6th, 2013 No comments

Death benefits – hardly a cheerful subject, and made no less gruesome by the fact that, as the body departs, the haunting specter of dependent benefits lingers.

Take, for example, the recent writ denied case of Jamie Xelowski (Dec.)/J. Campbell v. Community Health Network.

The facts are pretty simple – Jamie Xelowski sustained an industrial injury while employed by the Community Health Network/City and County of San Francisco, and, unfortunately, passed away as a result of her injury.  Her daughter, J. Campbell (“JC”), sought benefits under Labor Code section 3501, which provides that a child of any age found by any trier of fact to be physically or mentally incapacitated from earning, shall be conclusively presumed a total dependent.

And, as Labor Code section 4703.5 provides, in additional to the total death benefit for all of applicant’s dependents, the “physically or mentally incapacitated child” is entitled to temporary disability benefits until his or her death.  In short, a defendant is better off having an injured worker be found 100% permanently disabled rather than pass away.  Yes, yes, I know – I don’t like writing about this stuff too much for the very reason that it makes your humble blogger feel dirty for calculating how to minimize liability by wishing for one death or another.

So, back to the Xelowski case – JC had sought and received social security benefits in October of 2010, after her application was initially denied on May 5, 2010.  JC had appealed the first result, and her case was reviewed by an analyst and a physician.  There was no appearance on the part of JC at any Social Security Administration Hearing.

JC argued that the finding by the Social Security Administration triggers the effects of Labor Code section 3501, in that she is “a child of any age found by any trier of fact … to be physically or mentally incapacitated from earning.”  Defendant, not wanting to be stuck with an employee’s daughter’s lifetime of temporary disability benefits (it’s like having an employee on the payroll but not getting any work out of him or her) decided it might be worth a billable hour or two to fight.

The WCJ was persuaded – what happened before the SSA was the equivalent of a Panel Qualified Medical Evaluation – there was no judicial officer involved.  So, while JC might still prove her incapacity, mentally or physically, the presumption was not there yet.  Additionally, the finding still allowed JC to earn some income, so this finding did not satisfy the requirements of 3501.

Well, the WCAB didn’t agree – the panel of commissioners found that the Social Security Administration’s finding of disability triggered section 3501.

Now, your humble blogger has a bone to pick, but not with this particular case.  The Commissioners properly  applied section 3501, as it is, and when your humble blogger has to feed the meter in San Francisco, he can explain to his visiting friends why the meter makes more per hour than he does (San Francisco is self-insured, after all).

But, the proverbial bone your humble blogger has to pick is with the language of the statute itself.  Section 3501 conclusively presumes a fact (mental or physical incapacity) without affording the defendant fair notice of a hearing and an opportunity to be heard.

Picture, if you will, some poor unfortunate soul attending a hearing before the Social Security Administration, with proof of physical or mental incapacity, and some attorney like your humble blogger kicking down the hearing room doors and demanding to be heard because the poor soul’s mother or father works for his client.  “Her mother might die on the job, some day, and I want to make sure you don’t make a ruling that would affect us…”

Exactly – insanity.  The conclusive presumption should be done away with – if a person is found incapacitated from earning, then those same documents can be used to prove the case again before a workers’ compensation Judge.  After all, the SSA is giving away other people’s money, and might not be as zealous in its defense as a client with a million dollars on the line (picture $500 per week for 40 years).

If there is time for public comment at the next midnight reform session, perhaps we can bring this up?

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Another Touchdown for Pro-Sports Teams

April 19th, 2013 No comments

If things keep going like they’re going, Assembly Bill 1309 might become irrelevant after all.  The bill would effectively bar cumulative trauma claims for visiting professional athletes, and is of course meeting with opposition from the usual suspects.

But recently, a Missouri federal district court recently confirmed an earlier arbitrator’s award instructing several football players to file their claims in their home states and not in California.

But the NFL isn’t waiting for California to decide whether or not it wants to be on the receiving end of a boycott for games and training camps – Federal courts are deciding the issues in other states and are consistently telling professional athletes that they must honor their employment contracts and bring their claims for workers’ compensation in their home states.

If you’re not a California team owner, you should be scrambling to create some precedent in your home state for the fact that the forum-selection clause of the pro-sports employment contract is enforceable and requires a professional athlete to bring his or her claim for injury in the home-state of the team.

If the pro-sports teams continue to win victories outside of California, it won’t matter much what happens to AB 1309.

I know the applicants’ attorneys are all chomping at the bit to get pro-sports clients in California, and the defense attorneys are probably looking forward to all those extra billable hours as they valiantly defend this team or that from the meat-grinder of California’s Boards.  Your humble blogger it not among them – logic, reason, and basic fairness have to trump a paycheck once in a while, and this is that once-in-a-while.

There is no reason why an employer from Any-State should have to defend a claim in California and be liable for a California award when its employee has barely any connection to California.  And continued efforts to drag other teams here and milk them for dollars, which would flow to all the participants in the system, will end up costing California a lot of money – no more games, no more training camps (it simply won’t be worth it anymore).

Here’s hoping for more victories for the side of reason.

Have a good weekend!

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Judge Holds One Game in CA Establishes Career-long Jurisdiction

Today’s blog post is appropriately started with the words of one of America’s most profound and provocative modern poets – Shawn Corey Carter (also known as the rapper Jay-Z):

If you’re having cornerback problems, I feel bad for you son; I got 99 problems, but work comp. ain’t one.

Professional football has once again tackled (get it? Tackled? Football?) California workers’ compensation issues.  The latest claim to fall off the Ridiculous Tree and hit every branch on the way down is that of Michael Jameson v. Cleveland Browns.

Michael Jameson is a former cornerback who played three seasons for the Cleveland Browns (2001-2003) after playing college football for Texas A&M University.  As the names “Cleveland” and “Texas” suggest, Jameson had not been employed in California until he played one game here for the Browns.  This was the only game in his career that took place in California.  Applicant claimed that his career-wide cumulative trauma should be adjudicated under California law by a California WC

This topic may sound familiar as it was the subject of a 3-part post on California Workers’ Compensation Appeals Board jurisdiction over visiting employees.

The workers’ compensation Judge ruled that California did have jurisdiction over the matter because Labor Code section 3600.5(b) does not apply.  The WCJ found that the defense had not provided admissible evidence with respect to Ohio’s laws proving that applicant had an available claim in Ohio.

Your humble blogger’s favorite quote from the WCJ? “Since the applicant played in that game, and paid California taxes, the California Courts should be protective of California taxpayers and extend their jurisdiction to them to protect their rights as given to them by the California Legislature. Certainly, in other cases, this WCJ and all WCJs are very concerned with those other taxpayers, the employers, who undertake payroll taxes, business “licenses,” which are, of course, taxes, and countless other fees and extortions to ensure the pay and pension of California’s public servants. 

The defense attorney had cited Ohio cases and statutes, but the WCJ found that those citations were in the attorney’s brief and, therefore, were not “evidence.”  In all fairness, this is true – cases are not evidence or facts, but law.

On review, the WCAB granted reconsideration, ordering the WCJ to allow the parties to present additional evidence both as to the extent that the employer’s self-insurance covers out-of-state injuries and the law in Ohio.   It appears that it may be necessary for out-of-state employers to print out cases and statutes, mark them as exhibits, and move them into evidence.  Hopefully, the same rule will not one date apply to California case-law and statutes as well.

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