No Workers Comp for Football Injury
(CN) - A football player who was hurt trying out for the Seattle Seahawks is not entitled to workers' compensation benefits, the Washington Court of Appeals ruled.
Courtney Robinson returned kicks and played defensive back at the University of Massachusetts. He was not selected in the 2009 NFL draft.
Robinson signed as a free agent with the Philadelphia Eagles after the draft, but the team released him four months later.
During the 2009 season, Robinson tried to catch on with the Cincinnati Bengals and Detroit Lions, but neither team signed him.
In February 2010, Robinson hired agent Lyle Masnikoff. Two months later, the Seahawks flew Robinson from Connecticut to Seattle to join 15 other free agents for a three-day minicamp.
According to Seahawks Vice President of Football Administration John Idzik, prospects are asked, but not compelled, to undergo physical examinations and football drills with no pads or contact.
During orientation, Robinson and the other prospects signed liability waivers, stating that they are not employees of the team and would not hold the team liable for injuries.
Seahawks head coach Pete Carroll threw a ball to Robinson during a drill, and Robinson hurt his knee diving to catch the ball. He suffered a torn meniscus and was sent home on a flight that night.
Robinson applied for benefits from the Washington Department of Labor and Industries, which denied his claim. The Board of Industrial Appeals did the same.
Robinson then took his case to the Washington Court of Appeals, arguing that the team's control over his minicamp activities and payment of his expenses constituted an implied employment agreement.
Judge Ann Schindler disagreed.
"The record makes clear that participation in the minicamp was voluntary and the on-field drills at the minicamp were 'significantly different' from preseason or a game," Schindler wrote for the court.
Schindler also cited Robinson's past experience with NFL teams to assert that Robinson "knew an employment relationship with an NFL team did not exist unless the team made an offer and the parties executed a standard NFL player contract form."