EMANUAL DAVIS vs. ATLANTA HAWKS, FEDERAL INSURANCE (CHUBB GROUP OF INSURANCE COMPANIES), TIG INSURANCE COMPANY, HOUSTON ROCKETS, SEATTLE SUPERSONICS, LIBERTY MUTUAL INSURANCE COMPANY

This case concerns a professional basketball player's cumulative injury claim against former employers and their insurers. The Workers' Compensation Appeals Board (WCAB) affirmed an award to the applicant, finding California had jurisdiction based on the applicant's games played in the state and, potentially, a contract of hire in California. Defendants argued California lacked jurisdiction, citing Federal Insurance Co. v. Workers' Comp. Appeals Bd. (Johnson), which held that a single game did not create a substantial connection. However, the WCAB distinguished this case, finding the applicant's California exposure more than "de minimis" and noting the applicant's testimony about an injury sustained in California. One commissioner dissented, arguing the applicant's California games constituted less than 8% of his career and thus did not establish a "legitimate and substantial connection" for jurisdiction under Johnson.