By Dorothy Atkins
Law360, San Francisco (May 3, 2017, 12:46 PM EDT) —
A Texas federal judge on Tuesday remanded former Houston Texans and Philadelphia Eagles linebacker DeMeco Ryans’ personal injury lawsuit against his former teams and the National Football League, saying his claims aren’t preempted by federal law because their resolution doesn’t require an interpretation of his collective bargaining agreement with the NFL.
U.S. District Judge Kenneth M. Hoyt sent Ryans’ suit back to the court where the dispute originated, finding that Ryans’ negligence claims do not automatically require an interpretation of the CBA, but should instead focus on the conduct of the involved parties.
“While the court acknowledges that the CBA governs certain aspects of the plaintiff’s contractual agreement with the NFL, the court is of the opinion that the terms contained therein would not be implicated in the course of the plaintiff’s presentation of his negligence claims,” the judge said.
Ryans, who played for the Texans before being traded to the Eagles in 2012, was injured on the field at Houston’s NRG stadium in 2014 while playing for the Eagles against his former team.
He originally hit the Texans and the NFL with a $10 million lawsuit in Texas state court in October. Ryans claimed he suffered a career-ending, noncontact Achilles tendon injury due to unsafe “seams” in the removable natural grass surface at the stadium, which has since been replaced. The injury occurred when he landed on one of the seams after intercepting a pass.
The Texans took the case to federal court arguing that his claims are preempted by the federal Labor Management Relations Act and that the resolution of his claims require the interpretation of the CBA that governs the terms of the relationship between the NFL and its players.
In December, Ryans asked the court to remand the case, arguing that the suit should be handled in state court because his claims are not preempted by the LMRA. Ryans reasoned that his complaint disclaims any remedy under the CBA and that his claims are based on Texas tort law concepts that require no interpretation of the CBA.
Specifically, Ryans said he is bringing premises liability claims that are independent of the CBA, as they focus on the duty the Texans, as a lessee of the stadium, have to invitees to warn of and prevent dangerous conditions.
In February the team pushed back, arguing that Ryans’ case is the first of its kind and the two cases pointed to by Ryans, where the federal courts found injuries during games to be outside the CBA, are different from his and do not support remand of Ryans’ claims.
But on Tuesday, Judge Hoyt sided with Ryans, finding that the player’s premises liability claim under Texas state law is not inextricably intertwined with consideration of the CBA, because Ryans never invoked the CBA to satisfy any of the elements of his claim.
Ryans’ attorney Robert E. Ammons of The Ammons Law Firm LLP told Law360 Wednesday that he believes Judge Hoyt’s ruling is correct under the law and it’s “unfortunate” that the case had an unnecessary delay.
Counsel for both the Houston Texans didn’t immediately respond Wednesday to requests for comment.
Ryans is represented by Robert E. Ammons, Evan N. Kramer and Sydney Meriwether of The Ammons Law Firm LLP.
The Texans are represented by Wesson H. Tribble, Margaret J. Graeff and Dan P. McManus of Tribble Ross.
The case is Ryans v. Houston NFL Holdings L.P. dba Houston Texans et al., case number 4:16-cv-03554, in the U.S. District Court for the Southern District of Texas.
–Additional reporting by Rick Archer and Zachary Zagger. Editing by Rebecca Flanagan.