NFL Player Denied Right to Workers’ Compensation Benefits in California

Former professional football player Bruce Matthews was a 19 year veteran of the NFL who retired in 2002 when he was with the Tennessee Titans. In 2008, he filed a claim in California claiming a right to workers' compensation benefits, even though there was no specific injury in California. After the claim was filed, the Titans filed a grievance against Matthews arguing that the suit violated his employment contract which specifically provided that any workers' compensation claim would be governed by Tennessee law. Due to a binding arbitration clause in a collective bargaining agreement, the parties ultimately arbitrated the dispute. The arbitrator found the choice of law provision to be valid and controlling, and ordered Matthews to "cease and desist" with the filing in California. Subsequently, Matthews filed suit in federal court to vacate the arbitration award. The District Court denied his request and confirmed the Arbitrator's Award.

Matthews then filed an appeal, arguing that the arbitrator's award and the subsequent court decision contravened California workers' compensation policy and federal labor policy. The Ninth Circuit Court of Appeals disagreed, however. In analyzing the argument as it relates to California law, the Court noted that an employee who is otherwise eligible for California worker's compensation benefits cannot be deemed to have contractually waived such benefits. However, in this case, it is questionable whether Matthews was eligible for benefits in California as he had no specific injury and sought no medical treatment in California. In essence, Matthews failed to allege sufficient contacts with California to demonstrate that he was entitled to benefits under state law.