Court Exempted Atlanta Falcons From Injury Claim

A California appellate court ruled the team is not liable for a former player's workers compensation claim.

Updated on Oct. 9, 2026 in Football

Court Exempted Atlanta Falcons From Injury Claim

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Should professional athletes be able to file workers compensation claims in any state they once worked?

The California Court of Appeal has ruled that the Atlanta Falcons are exempt from a workers compensation claim filed by former NFL player Wayne Gandy. The court determined the team qualifies for an exemption because Gandy performed fewer than 20% of his duty days within California.

Why it matters

This ruling clarifies the application of statutory exemptions for professional athletes who play across multiple states. It limits the ability of former players to seek workers compensation in California if their career was primarily based in other jurisdictions.

Wayne Gandy played 15 NFL seasons throughout his professional career. The court found that Gandy performed fewer than 20% of his duty days in California, failing to meet the state threshold for the claim.

The players

Wayne Gandy

He is a retired NFL player who played 15 professional seasons before filing a workers compensation claim.

Atlanta Falcons

This is a professional NFL franchise that sought an exemption from a former player's compensation claim.

California Court of Appeal

This judicial body is responsible for reviewing and issuing rulings on state legal disputes.

Workers' Compensation Appeals Board

This agency handles disputes and claims related to workplace injuries and benefits in California.

Los Angeles Rams

This is an NFL franchise that signed Gandy to a contract in 1994.

The details

The court annulled a previous decision by the Workers' Compensation Appeals Board regarding Gandy's 2015 filing. The matter has now been remanded back to the board for further proceedings following the appellate court's finding.

1994: Gandy signed a contract with the Los Angeles Rams.
February 2009: Gandy retired from the NFL.
September 2015: Gandy filed a workers compensation claim.
October 7, 2026: The appeals court issued the ruling.

The Big Picture

This ruling applies California's workers compensation statutory exemption for professional athletes to players with limited service time in the state. It narrows the interpretation of jurisdictional eligibility for former NFL players seeking benefits.

The ruling prevents Gandy's claim from proceeding under current California standards for duty day calculations. The case now returns to the appeals board to resolve the claim in accordance with the court's finding.

The takeaway

This case highlights how interstate labor rules impact the legal eligibility of professional athletes for state-level benefits. Athletes must be aware that their historical duty days across different states can significantly influence their ability to pursue claims in specific jurisdictions.