A California appeals court has ruled that the Atlanta Falcons are off the hook for a workers' compensation claim filed by retired offensive lineman Wayne Gandy, who spent just one of his 15 NFL seasons with a California-based team. The decision turns on how little time Gandy actually logged working in the state during a career that stretched from 1994 to his retirement in February 2009.
The California Court of Appeal, Fourth Appellate District, Division Three, decided the case, Atlanta Falcons v. Workers' Compensation Appeals Board, on October 7, 2025, according to workerscompensation.com. The court found that the Falcons were exempt from California's workers' compensation law when it came to Gandy's cumulative-injury claim, the outlet reported.
Gandy, a former NFL player, began his career with the Los Angeles Rams in 1994, signing his initial contract in California, per a case brief from Mullen & Filippi. But starting in 1999, Gandy played exclusively for non-California teams — the Pittsburgh Steelers, the New Orleans Saints and finally the Atlanta Falcons — under contracts signed in other states, the firm's case brief states.
Why a Single California Contract Wasn't Enough
Gandy played 15 NFL seasons before retiring in February 2009, according to Business Insurance. Of those, he played only one season for a California-based team, spent fewer than 20% of his career duty days in California or with a California-based team, and played at least seven seasons for teams based outside the state, the outlet reported.
In September 2015, Gandy filed a California workers' compensation claim alleging cumulative injuries to multiple body parts, naming the Falcons along with several of his other former NFL employers, the same report states. The Workers' Compensation Appeals Board had initially sided against the Falcons, reasoning that jurisdiction existed because Gandy signed a California contract early in his career — the board rescinded an earlier decision on that basis, according to the Mullen & Filippi case brief.
Court Rejects the Jurisdiction Argument
The appeals court rejected that reasoning. It concluded that a single California contract or a single season of full-time, regular work in the state is not, by itself, enough to establish jurisdiction over a career-long cumulative-trauma claim, the firm's brief notes. Because all of Gandy's employers in his final season were otherwise exempt, and because he failed to meet the statutory conditions that would restore California jurisdiction, the law exempted both Gandy and the Falcons from coverage under the state's workers' compensation system, per the same case brief.
The exemption rests on California Labor Code sections 3600.5(c) and (d). Gandy performed fewer than 20% of his duty days in California during the relevant period, and the Falcons had provided workers' compensation coverage under another state's laws that also covered his work in California, the station's report states. The court also distinguished Gandy's situation from a prior case, Bowen v. Workers' Compensation Appeals Board, noting that Gandy's career continued for many years with non-California teams under contracts entered into in other states, per the same account.
What the Ruling Does and Doesn't Decide
The Court of Appeal annulled the board's decision and sent the matter back for further proceedings, Business Insurance reported. Its ruling addressed only the Falcons' liability, not that of Gandy's other former teams, the outlet noted — leaving open the question of whether he can still pursue claims against those other franchises.
The case echoes a separate, though unrelated, dispute before the California Workers' Compensation Appeals Board, in which a defendant similarly argued that a claim was barred under Labor Code section 3600.5(c) and (d) because the applicant hadn't spent more than 20% of his duty days in California during his final year as a professional athlete. As reported by Beinsure, the Gandy decision underscores how California courts are drawing firmer lines around which out-of-state athletes can bring cumulative-injury claims against teams with only a brief California connection.
