Matthews v. NFL Management Council

A claimant fails to establish that an arbitration award violates the public policy of one state where the claimant fails to allege that he suffered a specific injury in that state.

Bruce Matthews played football in the National Football League (“NFL”) from 1983 to 2002. During that time, Matthews played for three teams: the Houston Oilers, the Tennessee Oilers, and the Tennessee Titans. In 2008, Matthews filed for workers’ compensation in California for pain and disability stemming from injuries sustained throughout his career. Matthews did not allege that any particular injury took place in California, or that he even played in the state during that time. The NFL Management Council (“NFLMC”) and Tennessee Titans filed a grievance against Matthews for violating his contract, which stated that all workers’ compensation claims would be decided under Tennessee law. The parties arbitrated according to the NFL’s collective bargaining agreement. The arbitrator held in favor of NFLMC and the Titans, finding that Matthews’s workers’ compensation claim in California violated his contract. Matthews then filed a claim in federal district court to dismiss the arbitration decision, which was denied. Matthews appealed, claiming that the denial of his right to seek workers’ compensation benefits violated California public policy. The Court denied this assertion, stating that California workers’ compensation law covers employees who suffered an injury in California and were treated for the injury in California. Matthews simply stated that he had received injuries at “various” locations while playing football, and did not allege that any of his injuries took place in the state. Matthews further argued that the arbitration award violated the Full Faith and Credit Clause. The Court disagreed, because California has no absolute right to apply its laws, irrespective of contacts with the parties in question. The facts of this case do not show that the arbitrator chose to ignore law that was otherwise applicable. AFFIRMED.