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18 December 2025

California Court Finds Atlanta Falcons Exempt From Workers' Compensation Law In Wayne Gandy Case

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A California appellate court has found that the Atlanta Falcons are exempt from the state's workers' compensation law.
United States California Employment and HR
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A California appellate court has found that the Atlanta Falcons are exempt from the state's workers' compensation law. As a result, the Falcons are not responsible for former NFL player Wayne Gandy's workers' compensation claim.

Several years after his 2009 retirement Gandy, a 15-year NFL veteran, filed a workers' compensation claim against the Falcons, the Los Angeles Rams, the St. Louis Rams, the Pittsburgh Steelers, and the New Orleans Saints. In his suit, Gandy alleged that the Falcons, the last NFL team for which he played for three years before retirement, were liable for his claim.

The court found that Gandy, who played only one season for the L.A. Rams and spent less than 20% of his career in the state of California, could not claim coverage for his injuries under state law. The court's decision followed legal precedent stating that professional athletes are exempt from California's workers' compensation benefits for cumulative injuries, unless they spent at least 2 seasons, or at least 20% of their careers, playing for teams based in California. Players must also have spent fewer than 7 seasons playing in other states to be eligible for benefits. Therefore, professional athletes who mostly play out of state generally are not entitled to coverage under California law, even if they played for local teams for limited periods.

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