May 9, 2025 | Sacramento, CA – MedLegalNews.com — A California appellate court has remanded a case to the Workers’ Compensation Appeals Board (WCAB) to re-examine the appropriate injury date for a cumulative trauma claim brought by a retired Major League Baseball player.
The player, whose name remains confidential in court records, had an active professional baseball career between 1972 and 1979. Decades later, in 2011, he filed a cumulative trauma claim asserting that repetitive physical activity during his playing years caused lasting orthopedic and internal health conditions.
The determination of the correct date of injury is central to this case, as it impacts the statute of limitations, jurisdiction, and potential eligibility for workers’ compensation benefits under California law. The appellate court found that the WCAB had incorrectly used the player’s last employment date instead of thoroughly evaluating when the player became disabled and when he first knew, or reasonably should have known, that his injuries were work-related.
This decision highlights how cumulative trauma claims can present unique legal challenges, especially for retired athletes and workers in professions where injuries develop gradually over time.
Dispute Centers on Legal Injury Date
At the core of this cumulative trauma claim is a legal dispute over when the player’s injury officially occurred under California law. According to California Labor Code §5412, the legal date of injury in a cumulative trauma case hinges on two critical factors:
When the worker first became disabled.
When the worker knew, or should have reasonably known, that the disability was caused by their work activities.
The appellate court determined that the WCAB incorrectly used the player’s last employment date to establish the injury date. Instead, the board should have assessed the timeline of when the player became functionally disabled and when he recognized a connection between his symptoms and his professional baseball career.
“This error was not harmless,” the court emphasized, noting that accurately determining the date of injury directly influences the statute of limitations, jurisdiction, and the injured party’s eligibility for workers’ compensation benefits. An incorrect date can result in wrongful denial of claims or misapplication of state jurisdiction, especially for athletes or workers who spent much of their careers outside California.
For those navigating similar cases, understanding the nuances of cumulative trauma claims and Labor Code §5412 is essential. Attorneys, claims professionals, and injured workers must carefully document not just the progression of injuries, but also the moment of awareness linking those injuries to employment.
For a deeper dive into cumulative trauma case law and the implications of this ruling, visit WorkCompCentral’s analysis here.
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 has implications beyond retired athletes, highlighting challenges in long-delayed cases within professional sports, entertainment, and travel-heavy occupations, where a cumulative trauma claim may arise years after the physical strain of a career leads to lasting injuries.
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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When Should a Cumulative Trauma Claim Be Filed in California?
A cumulative trauma claim in California should be filed as soon as a worker becomes aware that their disability is connected to their job duties. Under Labor Code §5412, the clock for filing begins when the worker both experiences a disability and understands that their work contributed to it. Prompt filing is essential to avoid statute of limitations issues that could jeopardize eligibility for workers’ compensation benefits.