Travelers Indemnity Co. v. Workers Compensation Appeals Board

("Date of Injury" Is Determined under Labor Code Section 5412 When Deciding Whether to Send a Workers' Compensation Coverage Dispute to Mandatory Arbitration)

(September 2025) - In Travelers Indemnity Co. v. Workers' Compensation Appeals Board, 111 Cal. App. 5th 568 (May 7, 2025), the California Fourth District Court of Appeal addressed whether a dispute over insurance coverage in a workers' compensation case should be subject to mandatory arbitration under California Labor Code section 5275(a)(1). This case arose from a claim filed by George Zeber, a former professional baseball player, who alleged cumulative injuries sustained during his employment with the New York Yankees from 1968 to 1978. Travelers Indemnity Company ("Travelers") disputed whether the New York Yankees had workers' compensation coverage during that time. The Workers' Compensation Appeals Board ("WCAB") found that Zeber had sustained a compensable injury, but deferred any award pending