Authorities as the decision cited them, with how this panel applied each one.
California Labor Code
Labor Code section 3600.5
Provides jurisdiction over injuries arising out of employment outside California if contract of hire was made in California.
From the decision · page 5DISCUSSION
Labor Code section 3600.5(a)2 provides that, "[i]f an employee who has been hired or is
California Labor Code
Labor Code section 5305
Grants jurisdiction over injuries outside California if employee is California resident and contract of hire was made in California.
From the decision · page 5The Division of Workers' Compensation, including the administrative director, and
the appeals board have jurisdiction over all controversies arising out of injuries
suffered outside the territorial limits of this state in those cases where the injured
employee is a resident of this state at the time of the injury and the contract of hire
was made in this state. Any employee described by this section, or his or her
dependents, shall be entitled to the compensation or death benefits provided by this
division.
California Court of Appeal
Aetna Casualty and Surety Co. v. Workers' Comp. Appeals Bd. (Salvaggio) (1984) 156 Cal.App.3d 1097
Establishes burden of proof for contract of hire in California for jurisdiction.
From the decision · page 5The burden of establishing that a contract of hire was made in California rests with
California Supreme Court
Reynolds Electrical & Engineering Co. v. Workmen's Comp. Appeals Bd. (Egan) (1966) 65 Cal.2d 429
Contract formation rules apply to employment contracts for jurisdiction purposes.
From the decision · page 6California. (Aetna Casualty and Surety Co. v. Workers' Comp. Appeals Bd. (Salvaggio) (1984)
156 Cal.App.3d 1097, 1103 [203 Cal.Rptr. 396, 49 Cal.Comp.Cases 447]. A contract of
employment is governed by the same rules applicable to other types of contracts, including the
requirements of offer and acceptance. (Reynolds Electrical & Engineering Co. v. Workmen's
Comp. Appeals Bd. (Egan) (1966) 65 Cal.2d 429 [31 Cal.Comp.Cases 415].) Where parties have
agreed in writing upon the essential terms of a contract, there is a binding contract even though a
formal one is to be prepared and signed later. (Commercial Casualty Insurance Company of
Newark, New Jersey v. Indus. Acc. Comm. (Porter) (1952) 110 Cal. App. 2d 83 [17 Cal. Comp.
Cases 84].)
California Court of Appeal
Commercial Casualty Insurance Company of Newark, New Jersey v. Indus. Acc. Comm. (Porter) (1952) 110 Cal. App. 2d 83
Written agreement on essential terms creates binding contract for jurisdiction.
From the decision · page 6California. (Aetna Casualty and Surety Co. v. Workers' Comp. Appeals Bd. (Salvaggio) (1984)
156 Cal.App.3d 1097, 1103 [203 Cal.Rptr. 396, 49 Cal.Comp.Cases 447]. A contract of
employment is governed by the same rules applicable to other types of contracts, including the
requirements of offer and acceptance. (Reynolds Electrical & Engineering Co. v. Workmen's
Comp. Appeals Bd. (Egan) (1966) 65 Cal.2d 429 [31 Cal.Comp.Cases 415].) Where parties have
agreed in writing upon the essential terms of a contract, there is a binding contract even though a
formal one is to be prepared and signed later. (Commercial Casualty Insurance Company of
Newark, New Jersey v. Indus. Acc. Comm. (Porter) (1952) 110 Cal. App. 2d 83 [17 Cal. Comp.
Cases 84].)
California Supreme Court
Alaska Packers Asso. v. Industrial Acci. Com. (Palma) (1934) 1 Cal.2d 250
Contract of hire formed in California is sufficient for jurisdiction even if injury occurs outside California.
California Workers' Compensation Appeals Board
McKinley v. Arizona Cardinals (2013) 78 Cal.Comp.Cases 23
Employment contract made in California confers jurisdiction even if no games played in California.
California Workers' Compensation Appeals Board
Similar precedent confirming jurisdiction based on contract formation in California.