November 24, 2025 | SIBTF.org – The California Workers’ Compensation Appeals Board (WCAB) is under scrutiny after the Fourth District Court of Appeal questioned its authority to adjudicate claims filed by out-of-state professional athletes. The ruling highlights jurisdictional limits and emphasizes the importance of proper venue in complex workers’ compensation cases.
The appellate court ruling has major implications for insurers, employers, and claims administrators, particularly those managing high-profile or mobile employees such as professional athletes who perform in multiple states during their careers.
How the Fourth District Limited WCAB Authority
The court concluded that WCAB cannot automatically assert jurisdiction over athletes whose injuries or employment primarily occurred outside California. The decision focused on statutory thresholds outlined in California Labor Code § 3600.5(c) and (d), which determine when cumulative injury claims fall under WCAB authority.
The ruling signals that insurers and employers must scrutinize where claims are filed. For example, if an athlete works fewer than a statutory minimum of days in California, WCAB may lack authority to process the claim, even if the employee has a California contract. This clarification prevents improper claims from being adjudicated and protects employers from overpayment or legal exposure.
Why Jurisdiction Matters for Workers’ Comp Claims
Jurisdiction dictates which state laws and procedures govern claims. Filing in the wrong forum can result in:
- Overpayment of benefits
- Legal disputes or appeals
- Delays in claim resolution
For professional athletes who travel and compete across multiple states, filing in the correct jurisdiction is critical to ensure claims are handled lawfully. This decision also reinforces compliance for insurance carriers and claims administrators, who must now verify employment location data and cumulative work history before processing claims.
What Employers and Insurers Should Do
- Review policies covering out-of-state employees or athletes.
- Confirm claim filing locations to ensure WCAB has legal authority.
- Consult legal counsel for multi-state or complex claims.
Adopting these practices reduces risk, supports proper claim administration, and avoids costly litigation. For insurers, verifying jurisdiction upfront is now more critical than ever due to this Fourth District ruling.
Historical Context of WCAB Jurisdiction Cases
This is not the first time WCAB’s reach has been questioned. Courts have previously ruled that the board cannot exceed statutory authority, particularly in cases involving employees with multi-state careers or temporary assignments. However, the recent decision explicitly addressed professional athletes, clarifying that California cannot unilaterally adjudicate cumulative injury claims when statutory thresholds are unmet.
This precedent may also influence other mobile or seasonal workforces, including entertainers, contractors, and traveling healthcare professionals. Insurers should take note, as multi-state claims could be vulnerable to similar jurisdictional challenges.
For additional legal insight, see the Fourth District Court opinion.
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FAQs: WCAB Overreach and Out-of-State Claims
What is WCAB overreach?
WCAB overreach occurs when the board assumes authority over claims outside its legal jurisdiction, exceeding statutory limits.
How did the Fourth District rule on this issue?
The court held that WCAB cannot hear claims from out-of-state athletes unless statutory thresholds under LC §3600.5(c) and (d) are satisfied.
Who is impacted by this decision?
Employers, insurers, claims administrators, and professional athletes with multi-state employment agreements.
How can employers ensure compliance?
Employers can reduce risk and maintain compliance by carefully reviewing their workers’ compensation policies, especially for employees who travel or work across multiple states. It’s essential to confirm that claims are filed in the correct jurisdiction to avoid overpayment, legal disputes, or delays in resolution. Additionally, employers should consult experienced legal counsel to interpret complex multi-state regulations and ensure that contracts, coverage, and reporting practices align with current laws. Implementing regular internal audits and training HR or claims staff on jurisdictional rules can further strengthen compliance and minimize exposure to WCAB overreach challenges.