Can a Tennessee Titan Seek Workers' Comp in California?

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Football is a violent game, and many of the warriors who play it professionally find their careers cut short by brutal injuries. Even those players who are able to complete an entire career without incident may find themselves plagued by disabling pain and lingering injuries during their retirement years. Some of these players will file workers' compensation claims in the state where their team is based. But what happens when a player starts his career in Texas, finishes his career in Tennessee, and then files his workers' compensation claim in California? Is such a claim permissible? In Matthews v. Nat'l Football League Mgmt. Council (9th Cir. Aug. 6, 2012), the NFL Management Council (NFLMC) and the Tennessee Titans argued "no," and in light of the facts of the case, the Court of Appeals for the Ninth Circuit agreed.

Oilers and Titans fans will remember the plaintiff in Matthews, Bruce Matthews, as one of the greatest linemen ever to play the game. During his nineteen-year career in the NFL (1983-2001), Matthews played in fourteen Pro Bowls, and never missed a game due to injury. But approximately five years after retirement, Matthews filed a workers' compensation claim in California, citing ailments that had accrued over the course of his long career.

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