NFL Falcons Can't Seek Benefits in California
ATLANTA (CN) - Former Atlanta Falcons players who signed employment contracts in Georgia cannot seek workers' compensation in California, a federal judge ruled.
Nine athletes who played for the NFL Falcons between 2002 and 2010 filed for workers' compensation benefits in California, alleging their injuries had resulted from various Falcons games, including ones played in California.
But the Atlanta Falcons and the National Football League Management Council sought arbitration, arguing that their contracts with the players were subject to Georgia's workers' compensation law. The football club pointed out that all home games and practices occur at its Georgia headquarters. During the years of the nine players' employment, the Falcons played just four of 186 professional games in California, it said.
After the arbitrator barred the players from bringing their claims under California's workers' compensation law, the club and the NFLMC sought to confirm the award in the U.S. District Court for the Northern District of Georgia.
The players asked the court to vacate that award, which they said violated state and federal public policy.
U.S. District Judge Thomas Thrash found that the contract provision that obligated the players to seek benefits in Georgia did not violate Georgia public policy. Whereas the players had extensive contacts with Georgia, they had very few contacts with California, Thrash found.
The award neither relieves the Falcons of obligations under Georgia's workers' compensation law, nor allows the players to receive compensation that would exceed the total sum provided by Georgia law, according to the 20-page ruling.
Thrash noted that statutory workers' compensation claims can be subordinated to valid contractual limitations, such as the ones enforced by the arbitration award.
He also rejected the players' claim that the award violated California public policy, noting that the players never proved they were explicitly injured in California, where they had played only two percent of their Falcons games.
"As discussed, the players' tenuous connection with California may not even implicate the state's workers' compensation system," the ruling states. "On the other hand, the players have extensive contacts with Georgia, including playing and practicing in Georgia as well as contracting for Georgia benefits. None of the authorities proffered by the defendants requires the application of the law of a forum other than Georgia."
Thrash confirmed the arbitration award, noting its compliance with federal labor policy.