MICHAEL BARROW vs. WASHINGTON REDSKINS, DALLAS COWBOYS FOOTBALL CLUB, NEW YORK GIANTS, TENNESSEE TITANS, CAROLINA PANTHERS, GREAT DIVIDE INSURANCE administered by BERKLEY SPECIALTY UNDERWRITING MANAGERS, LLC, LEGION INSURANCE in liquidation by CIGA, TRAVELERS

The Workers' Compensation Appeals Board (WCAB) rescinded a prior finding that it had jurisdiction over the Dallas Cowboys for applicant Michael Barrow's injury claim. The WCAB determined that while applicant's agent, a California resident, negotiated the contract and communicated acceptance from Los Angeles, this action alone did not establish a "contract of hire" made in California. Crucially, the applicant himself was not in California at the time of acceptance, and the contract required his personal signature to be fully binding. Therefore, the WCAB lacked jurisdiction over this extraterritorial claim against the Dallas Cowboys.