On October 1, 2015 the Court of Appeal of California, Second Appellate District, concluded that former NBA player Durant “Rudy” Macklin was entitled to workers’ compensation benefits.
Macklin, a former Louisiana State University standout, was drafted by the Atlanta Hawks and played two seasons with the team before being traded to the New York Knicks. Macklin would later sign a contract with the Los Angeles Clippers though he never played an NBA game for the team. Macklin alleged: (i) that while he was with the Hawks, he played three games in California; (ii) that while he was with the Knicks, he played one game in California and he traveled to California for two additional games but did not actually play in those contests, and (3) that while he was with the Clippers, he attended a training camp and preseason games in 1984 before he was released. Macklin testified that he was never aware of any potential rights he had with respect to workers’ compensation until another NBA player told him of the same in 2011.
At the trial level, the workers’ compensation judge found that there was jurisdiction over all three NBA teams and that California was a proper venue because a portion of the cumulative injuries Macklin claimed (including the back and other body parts) arose there. Finally, the judge found that the claim was not barred by any statute of limitations as Macklin was unaware of any rights he had with respect to workers’ compensation. The Appeals Board affirmed the workers’ compensation judge’s opinion and maintained that there was more than a “de minimis connection between the injury” and California.
On appeal and among other arguments, the Knicks maintained that Macklin had no sufficient connection with California such that it should be liable as claimant played only one game for the Knicks in the state. The Court of Appeal concluded that because claimant was subsequently employed by the Clippers, it need not determine whether the remaining contacts (including seven games and additional practices) were sufficient to confer jurisdiction but that Macklin was entitled to California workers’ compensation benefits.
For more, see New York Knickerbockers v. Workers’ Comp. Appeals Bd., 2015 Cal. App. LEXIS 869 (October 1, 2015).