688 F.3d 1107
9th Cir.2012Background
- Matthews played 19 seasons in the NFL (1983–2002) for the Oilers/Titans and retired in 2002.
- In 2008, Matthews filed a California workers’ compensation claim alleging cumulative injuries from his career.
- Titans and NFLMC asserted a Tennessee choice-of-law clause precluded California benefits; dispute resolved by binding arbitration under the NFL CBA.
- The arbitrator held Matthews’ claim must be decided under Tennessee law and ordered him to cease pursuing California benefits.
- Matthews sought to vacate the award under the LMRA; the district court denied vacatur and confirmed the award.
- Appellate review is de novo on legal questions; Matthews lacks the California contacts to bring his claim within California’s workers’ compensation regime.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Scope of California workers’ compensation regime | Matthews: California policy applies despite no California injury | Titans/NFLMC: Tennessee law governs per contract | Not within California scope; no violation found |
| California public policy against waivers | No waiver of California benefits allowed | Policy not triggered absent California injury/contacts | Not violated given lack of California contacts/status of injury |
| Manifest disregard of Full Faith and Credit Clause | Award ignores California law under Full Faith and Credit | Arbitrator did not ignore explicit governing law | No manifest disregard; no clearly applicable law shown to be ignored |
Key Cases Cited
- Alaska Packers Ass’n v. Indus. Accident Comm’n, 294 U.S. 532 (U.S. 1935) (state interest in employment relationships; injuries and resources justify applying state law)
- Pacific Employers Ins. Co. v. Indus. Accident Comm’n, 306 U.S. 493 (U.S. 1939) (state interest in bodily safety and economics of injured employees; application of state law appropriate when injury occurs in state)
- Foster Poultry Farms v. NLRB, 74 F.3d 169 (9th Cir. 1995) (public policy against arbitrary enforcement of arbitration awards)
- Misco, Inc. v. United States, 484 U.S. 29 (U.S. 1988) (public policy exception to arbitration limited; must show explicit policy)
- Carter v. Health Net of Cal., Inc., 374 F.3d 830 (9th Cir. 2004) (manifest disregard standards in FAA review; reference for scope of review)