- A California appeals court ruled that the Atlanta Falcons were exempt from liability for former NFL player Wayne Gandy’s cumulative injury claim under state workers’ compensation law.
- Gandy spent fewer than 20% of his career duty days in California or with California-based teams and played only one season for a California franchise, falling outside the statutory requirements.
- The court overturned the Workers’ Compensation Appeals Board’s decision and returned the case for further proceedings, limiting its ruling to the Falcons’ liability.
A California appeals court ruled that the Atlanta Falcons were exempt from liability under the state’s workers’ compensation law for cumulative injuries claimed by former NFL player Wayne Gandy, despite his earlier employment with a California-based team.
In its October 7, 2025, decision in Atlanta Falcons v. Workers’ Compensation Appeals Board, the California Court of Appeal, Fourth Appellate District, Division Three, rejected the compensation board’s interpretation of statutory exemptions governing professional athletes who work across multiple states.
Gandy played 15 seasons in the NFL before retiring in February 2009. He began his career with the Los Angeles Rams in 1994, signing his employment contract in California, and continued under that agreement after the franchise relocated to St. Louis. He subsequently played for the Pittsburgh Steelers, New Orleans Saints and Atlanta Falcons.
In September 2015, Gandy filed a California workers’ compensation claim alleging cumulative injuries affecting multiple body parts. His claim identified several former NFL employers, including Atlanta.
The Workers’ Compensation Appeals Board determined that Gandy’s original California employment contract established jurisdiction over his claim, notwithstanding statutory exemptions for professional athletes.
The appellate court disagreed, finding that the Falcons qualified for exemptions under California Labor Code Section 3600.5(c) and (d).
The Falcons had provided workers’ compensation coverage under another state’s laws, including protection for Gandy’s work performed in California. During the relevant 365-day period, he completed fewer than 20% of his duty days in the state, satisfying the exemption for athletes temporarily working in California.
The court also examined Gandy’s broader employment history.
Although he had signed a contract in California, he played only one season for a California-based franchise and spent fewer than 20% of his career duty days in California or with California-based teams.
He also exceeded the statutory threshold of seven seasons with teams based outside California.
Under the applicable provisions, his employment history did not meet the conditions necessary to avoid the exemption from California workers’ compensation coverage.
The court concluded that a previous California employment contract does not automatically override the specific statutory restrictions governing professional athletes’ cumulative injury claims. It annulled the Workers’ Compensation Appeals Board’s decision and remanded the matter for further proceedings.
The ruling applies exclusively to the Atlanta Falcons’ liability under California law and does not determine whether Gandy may pursue compensation claims against his other former NFL teams.
