Retired NFL Player Cannot File for Workers’ Comp Benefits in California

By Sheena Harrison

Aug. 7, 2012

A retired National Football League player cannot file for workers’ compensation benefits in California because he did not prove that he suffered injuries in the state, the 9th Circuit U.S. Court of Appeals ruled Monday.

Bruce Matthews played for the Houston Oilers, Tennessee Oilers and Tennessee Titans, and retired from the NFL in 2002 after 19 years in the league, court records show.

He filed a workers’ comp claim in California in 2008. He claimed in filings to have been injured in “various” locations during his NFL career, but did not say any particular injuries had occurred in California.

A loophole in the NFL’s collective bargaining agreement allows players to file workers’ comp claims in states where their teams are not based. In particular, California law allows players to make a claim in California if they have played at least one game in the state.

Still, the Titans and the NFL Management Council sought to block Matthew’s comp claim under a binding arbitration agreement, which said Titans players’ claims should fall under Tennessee workers’ comp law. Last year, the U.S. District Court in San Diego denied a motion from Matthews to vacate the arbitration award.

Matthews appealed, arguing that the arbitration award violates federal labor laws and California workers’ comp law.

But in a unanimous decision Monday, the appeals court upheld the district court decision. It said California workers’ comp law doesn’t apply to Matthews because he did not clearly show that he was injured in the state, even though he played 13 games in California during his career.

The court also disagreed with Matthews’ argument that games he played in California contributed to cumulative, unspecified ailments that he now suffers.

“He did not allege any specific injury in California or a need for medical services in California,” the ruling reads. “Matthews likewise did not allege in his complaint before the district court that he suffered any discrete injury in California. Nor has he directed us to anything in the record indicating that he tried to prove injury in California, or any burden on the state’s resources.”

The court noted that employees cannot bargain away state minimum labor standards in arbitration or collective bargaining agreements. But it said that argument does not apply in Matthews’ case, because he did not prove that he has a claim under California workers’ comp law.

Sheena Harrison writes for Business Insurance, a sister publication of Workforce Management. To comment, email

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Sheena Harrison writes for Business Insurance, a sister publication of Workforce Management.

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