The Court of Special Appeals of Maryland ruled on August 26, 2026, that Curtis Brooks, a professional football player, is a covered employee under Maryland's workers' compensation laws. This decision came after Brooks sustained an injury during training with the Washington Commanders, a National Football League (NFL) team. The ruling is significant as it clarifies the legal status of professional athletes regarding workers' compensation, especially when their employment involves multiple states.
The case, titled In the Matter of Curtis Brooks (Docket No. 0549/25), began when Brooks filed a workers' compensation claim after rupturing his Achilles tendon during practice on August 6, 2023. The Maryland Workers' Compensation Commission initially denied his claim, stating that Brooks was not a covered employee because he had not performed any job duties in Maryland at the time of his injury. Brooks appealed this decision, leading to a ruling from the Circuit Court for Prince George’s County that reversed the Commission's decision.
The parties involved in this case are Curtis Brooks, the appellee, and Pro-Football, LLC, which operates the Washington Commanders, the appellant. Brooks was hired by the Commanders on August 3, 2023, and sustained his injury just three days later during a training camp practice in Virginia. The Commission's denial of Brooks's claim was based on the interpretation of Maryland's labor laws, specifically whether he qualified as a covered employee under Maryland's workers' compensation statutes.
The Circuit Court for Prince George’s County ruled that Brooks was indeed a covered employee under Maryland law. The court found that even though Brooks had not yet played in any games in Maryland, he had a valid employment contract with the Commanders that anticipated his participation in games in Maryland. The court stated, "At the time of his injury, Mr. Brooks was employed by the Team and anticipated remaining in his employment by Appellant until March 2024." This ruling was based on previous cases involving professional football players in Maryland, which established that the primary purpose of their employment is to play in games, regardless of where the actual training takes place.
The Court of Special Appeals affirmed the Circuit Court's decision, stating that the lower court did not err in its judgment. Judge Berger, who authored the opinion, referenced previous cases such as Pro-Football, Inc. v. Tupa and Pro-Football, Inc. v. McCants to support the finding that Brooks was a covered employee. The court emphasized that the nature of a football player's employment is defined by their participation in games, not merely by their practice locations. The court noted, "The purpose of a football player’s employment with a professional football team is to play in professional football games. It is not... to practice."
This ruling has significant implications for professional athletes and their rights to workers' compensation benefits. It establishes that even if a player has not yet participated in games, they can still be considered a covered employee if their contract anticipates their involvement in games, particularly if those games are held in Maryland. This decision reinforces the notion that the employment relationship and the expectations set forth in contracts are crucial in determining workers' compensation eligibility.
The ruling may also set a precedent for future cases involving athletes and workers' compensation claims, particularly in sports leagues where players often move between states for training and games. The decision clarifies that the primary focus should be on the employment relationship and the expectations of the contract rather than the specific location of practice or the timing of injuries.
Looking ahead, it is unclear whether the Washington Commanders will appeal this decision to a higher court. However, the ruling is currently binding and will require the Maryland Workers' Compensation Commission to reconsider Brooks's claim in light of the court's findings. As the landscape of professional sports continues to evolve, this case may play a pivotal role in shaping the rights of athletes regarding workers' compensation and their protections under state law.