Bush v. St. Louis Rams
United States District Court for the Eastern District of Missouri
2016 WL 3125869 (2016)
Running back Reggie Bush (plaintiff) suffered a season-ending knee injury when he slipped on a concrete surface bordering the turf while playing an away game against the St. Louis Rams (defendant), and sued the Rams in state court under state tort law, alleging their negligent maintenance created an unreasonably dangerous condition. The Rams removed the case to federal court, arguing the NFL's collective bargaining agreement (CBA) — which addressed player safety education and stadium playing-surface committees — governed and preempted Bush's state-law claim under federal labor law; Bush moved to remand to state court.
Whether a professional football player's claim that he was injured due to the negligent maintenance of a playing field is governed by the common-law duty of care that teams owe to invitees.