Court Exempted Atlanta Falcons From Workers' Claim
A California appeals court ruled on October 7, 2025, that the team is not liable for a former player's compensation claim.
Updated on Oct. 13, 2026 in Football
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The California Court of Appeal issued a ruling on October 7, 2025, exempting the Atlanta Falcons from workers' compensation liability for former NFL player Wayne Gandy. The decision overturned a previous finding by the Workers' Compensation Appeals Board.
Why it matters
The court found that Gandy failed to meet statutory requirements to override professional athlete exemptions under California labor law. This decision clarifies how duty day percentages and out-of-state employment history influence legal liability for California-based claims.
Gandy played 15 total seasons in the NFL and spent fewer than 20% of his duty days within California during his career. He exceeded the statutory threshold of seven seasons with teams based outside the state.
The players
Wayne Gandy
He is a former NFL player who participated in 15 seasons before retiring in 2009.
Atlanta Falcons
This is an NFL franchise that was granted an exemption from workers' compensation liability in this case.
Workers' Compensation Appeals Board
This state agency handles disputes regarding workplace injury claims in California.
California Court of Appeal
This is the state appellate court that reviewed and remanded the compensation case.
The details
The court applied California Labor Code Section 3600.5 to evaluate Gandy's eligibility, noting he had provided workers' compensation coverage under another state's laws while with the Falcons. Because he did not meet the necessary criteria for California-based claims, the court annulled the previous board decision.
Timeline
Wayne Gandy began his professional career with the Los Angeles Rams in 1994.
Gandy retired from the NFL in February 2009.
The workers' compensation claim was filed by Gandy in September 2015.
The California Court of Appeal issued the final ruling on October 7, 2025.
Season Trajectory
This ruling refines the application of California Labor Code Section 3600.5 to professional athletics. The court's interpretation confirms a narrower scope for out-of-state teams facing liability in the California workers' compensation system.
The ruling establishes that former players who spent the vast majority of their careers with teams outside California are unlikely to successfully claim workers' compensation within the state. This creates a significant precedent for how teams calculate and manage liability for players with multi-state career histories.
The takeaway
This decision underscores the importance of career-wide duty day logs for former professional athletes pursuing injury claims. Understanding state-specific statutory thresholds is essential for determining if a player is eligible to seek compensation under California labor law.
Further reading
For more on legal issues in the sport, see our California Football section.
Source note: This article includes information reported by Beinsure: Insurance & InsurTech Media Market Intelligence Platform.
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