California Court Rules NFL Team Exempt from Workers’ Comp Claim by Retired Player

A recent California appellate ruling underscores the jurisdictional boundaries that can limit professional athletes’ access to workers’ compensation benefits under California law—a decision with implications for insurers and adjusters handling cumulative trauma claims.

Former Atlanta Falcons offensive tackle Wayne Gandy filed a workers’ comp claim in California in 2015, alleging cumulative injuries sustained over his 15-season NFL career. The claim listed five teams as employers, including the Los Angeles Rams, St. Louis Rams, Pittsburgh Steelers, New Orleans Saints, and the Falcons. Although Gandy played only a small number of games in California during his time with the Falcons, he argued that the long-term wear and tear justified coverage under California’s relatively favorable workers’ comp statutes.

The Falcons disputed the claim, arguing their exemption as a non-California employer. A California appellate court sided with the team, concluding that Gandy failed to meet the statutory thresholds added in 2013 to curb forum-shopping by out-of-state athletes. These reforms require either two full seasons or 20% of a player’s career to be spent in California, along with fewer than seven seasons outside the state. Gandy played just one season in California and spent 14 seasons with non-California teams, falling well short of these thresholds.

For insurance claims professionals, this case offers a clear example of how legislative changes affect cumulative injury claims involving out-of-state employers. It also highlights the importance of jurisdictional analysis in multi-employer injury cases, especially when dealing with high-mobility professions like professional sports. Adjusters should be aware of the specific statutory metrics that determine eligibility for claims under California law and monitor how courts interpret evolving eligibility requirements for cumulative trauma claims.