Court: MLB Team Could Have Anticipated Claims Arising in Maine

Jan 30, 2009

The Supreme Court of Maine has affirmed the ruling of a hearing officer with the Maine Workers’ Compensation Board, who had held that the board had jurisdiction over the Houston Astros for purposes of a player’s workers’ compensation benefits and the payment of his medical and related services.
Eric D. Cavers was a baseball player and a resident of Maine who had signed a minor league baseball contract with the Houston Astros baseball organization. While playing a game in Tennessee in 2004, he injured his shoulder.
The contract he had with Astros obligated the baseball club to pay medical expenses caused by any playing injury and not covered by workers’ compensation or medical insurance. The club reserved the right to select the persons performing medical services and the places where such services would be performed.
Cavers ultimately selected a doctor in Massachusetts to perform arthroscopic surgery on his shoulder.
Cavers filed a petition for award of workers’ compensation benefits and for payment of medical and related services in Maine. Before the Workers’ Compensation Board, the Astros moved to dismiss the claim, asserting that Maine lacks personal and subject matter jurisdiction. The hearing officer found that Cavers was a resident of Maine at the time of the injury, and thus, the Board had subject matter jurisdiction over the claim. The hearing officer also determined that the Board had personal jurisdiction over the Astros.
Further, the hearing officer determined that Cavers was entitled to the protection of the Maine Workers’ Compensation Act for the 2004 shoulder injury, but awarded no wage replacement benefits. The petition for payment of medical bills was granted. The Astros filed a petition for additional findings of fact and conclusions of law, which the hearing officer denied. The Supreme Court granted the Astros’ petition for appellate review pursuant to M.R. App. P. 23 and 39-A M.R.S. § 322 (2007). The only issue raised by the Astros on appeal is whether the Board has personal jurisdiction over the Astros.
The baseball team argued that the exercise of personal jurisdiction in the case under Maine’s long-arm statute, Me. Rev. Stat. Ann. tit. 14, § 704-A (2007), violated due process because the only contact the team had with Maine was a visit by its director of scouting to negotiate and sign the player’s contract. On appeal, the court noted that the baseball team did not argue that the player was not a resident of Maine. The court found that the baseball team had sufficient contacts with Maine to have reasonably anticipated a court or administrative action in Maine arising from the player’s employment contract negotiated and signed in Maine. Moreover, the fair play and substantial justice element of the balancing test favored the acceptance of jurisdiction by the Workers’ Compensation Board as consistent with the constitutional requirements of due process under Me. Const. art. I, § 6-A and U.S. Const. amend. XIV, § 1.
The court further elaborated on the specific circumstance: “The Minor League Uniform Players Contract does not anticipate or direct that claims or disputes under the contract be brought in any particular jurisdiction or before any particular forum. A player signing such a contract, and the team that signs the player, both may reasonably anticipate that, because the player may travel and the contract may be assigned, the player might play baseball and be injured in most, if not all, of the fifty states, and that claims may arise in any state where the player plays or an injury occurs.
“Major League Baseball and its teams may anticipate actions in any state, and have significant resources to appear and defend such actions. Injured former players, unable to play and released from their contracts, would likely have great difficulty litigating to secure benefits in forums far from their state of residence.
“The same may be said of minor league ball players, released after injury and returned home, far from the team that signed them, to start a new career and get on with their lives. The fair play and substantial justice element of the balancing test favors the acceptance of jurisdiction by the Workers’ Compensation Board as consistent with the constitutional requirements of due process.”
Eric D. Cavers v. Houston McLane Co., INC. d/b/a The Houston Astros Baseball Club; Supreme Ct. of Maine; Docket: WCB-08-14, 2008 ME 164; 2008 Me. LEXIS 166; 10/30/08
Attorneys or Record: (for plaintiff) William O. LaCasse, Esq., C. Lindsey Morrill, Esq. (orally), Norman, Hanson & DeTroy, LLC, Portland, Maine. (for defendant) Patrick M. Kelly, Esq. (orally), McTeague, Higbee, Case, Cohen, Whitney & Toker, P.A., Topsham, Maine.


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