Experience. Knowledge. Results.

Experience. Knowledge. Results.

Football Player Not Entitled to Compensation Benefits Because League Did Not Sign Contract

On Behalf of | Jun 20, 2017 | Workers' Compensation Case Law |

In a recent decision, a Florida court of appeals determined that a football player whose contract was not renewed for the following season and who then injured himself during tryouts was not entitled to workers’ compensation benefits despite a contract between him and the team. The court explained that although the team and the player had signed an employment contract that had not yet expired, the football league had never signed the contract.

The Facts of the Case

The football player had played for one year with the Orlando Predators, a team in the Arena Football League, but his contract was not renewed. He tried out again for the team, and on the second day of tryouts, he suffered an injury. He filed for workers’ compensation benefits, but the AFL contended they were not required to provide him with benefits.

The issue was whether the football player was an AFL “employee.” The football player argued he was entitled to benefits because he had signed a contract that stated that he was hired for employment from February to August of that year. He was injured at tryouts in July, one month before the contract ended. However, although the player and the team representative had signed the contract, the AFL never signed it.


The player pointed to language in the contract that stated that the AFL’s Director of Football Operations had the right to disapprove the contract, and without disapproval within seven days, approval was automatic. Despite this, the court determined that if the contract was never formed in the first place, the automatic approval was never triggered—and since there was no AFL signature, the contract was never formed. The player also argued that the AFL assented to the contract in other ways. Yet the court rejected this, finding that the AFL’s decision to let him participate in the tryouts did not mean it assented to hiring him for the whole season. For these reasons, the court found there was no employee-employer relationship when he was injured, and the player was not entitled to benefits.

Employment Relationship Requirement in Workers’ Compensation Claims

In order for an individual to receive workers’ compensation benefits, an employment relationship must exist between the individual and the entity. The individual claiming benefits has the burden to prove that he or she is an employee. Georgia courts have held the Georgia Workers’ Compensation Act should be liberally interpreted in favor of an employment relationship. However, whether an individual is an employee is a determination made by the State Board of Workers’ Compensation.

Do You Have a Workers’ Compensation Claim?

If you were injured and believe you may be entitled to workers’ compensation benefits, talk to an experienced workers’ compensation attorney as soon as possible. Although an employment relationship is straightforward in some cases, some individuals, such as contractors, may have to prove that an employment relationship exists. At J. Franklin Burns, P.C., our Georgia workers’ compensation attorneys have 50 combined years of trial experience. To set up a free consultation about your claim, call us at 404-920-4708 or fill out our online form.