Atlanta Falcons v. WCAB, 114 Cal. App. 5^th 1268 (2025)

Wayne Gandy spent 15 years as a professional football player with the NFL. He played with the Los Angeles Rams during the 1994 season before the team moved to St. Louis, but never again played for a California team. Six years after his retirement from the Atlanta Falcons in 2009, Gandy filed a claim in California for workers’ compensation benefits, claiming a cumulative injury to multiple body parts. The workers’ compensation judge concluded that the Falcons were exempted from liability under California workers’ compensation law pursuant to Cal. Lab. Code §§ 3600.5(c) and (d).; the judge also held that Gandy was exempted from coverage under the same provisions. The California Workers’ Compensation Appeals Board (WCAB) rescinded the judge’s decision. The Court of Appeal annulled the WCAB’s opinion, noting that “the legislature’s purpose [in enacting these laws] was to essentially prohibit professional athletes employed by out of state teams from filing California workers’ compensation claims.”