Court Sends Back 1970s Baseball Player’s Cumulative Trauma Claim to Determine Injury Date

May 9, 2025 | MedLegalNews.com – California
A California appellate court has sent a case back to the Workers’ Compensation Appeals Board (WCAB) to determine the correct date of injury for a cumulative trauma (CT) claim filed by a retired Major League Baseball player.

The player, who remains unnamed in court documents, played professionally from 1972 to 1979. In 2011, he filed a CT claim alleging that repetitive motion caused long-term orthopedic and internal injuries.

Dispute Centers on Legal Injury Date

At issue is the date the injury legally occurred. Under California’s Labor Code §5412, the date of injury for cumulative trauma depends on two factors:

  1. When the worker first became disabled, and
  2. When the worker knew or should have known the disability stemmed from work.

The appellate court said the WCAB wrongly relied on the player’s last employment date to define the injury date. Instead, the board should have examined when he became disabled and aware of the job connection.

“This error was not harmless,” the court wrote. Determining the correct date is crucial because it affects the statute of limitations, jurisdiction, and benefit eligibility.

Why Jurisdiction Matters

The player hadn’t worked in California since the 1970s and played for out-of-state teams. If his injury occurred outside California, the state might lack jurisdiction over his claim.

The court directed the WCAB to gather more facts, including:

  • When his disability began
  • When he connected his symptoms to his baseball career

By clarifying these details, the WCAB can properly decide whether California law applies.

Implications Beyond Baseball

This ruling impacts more than retired athletes. It raises important questions for long-delayed claims in professional sports, entertainment, and travel-based jobs, where injuries often emerge years after retirement. Cumulative Trauma Claim

Attorneys and claims professionals should watch how courts interpret Labor Code §5412. The outcome could shift jurisdiction and benefit determinations in older CT claims.

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