In the Matter of Brooks

Court of Special Appeals of Maryland·Decided August 26, 2026·No. 0549/25·Published

Opinion

In the Matter of Curtis Brooks, Case No. 549, Sept. Term, 2025, Opinion filed on August 26, 2026, by Berger, J.

LABOR AND EMPLOYMENT – WORKERS’ COMPENSATION – COVERED EMPLOYEE – SITE OF EMPLOYMENT Pursuant to § 9-203(a)(2) of the Labor and Employment Article, an individual is a covered employee when he or she is working for the employer “outside of [Maryland] on a casual, incidental, or occasional basis if the employer regularly employs the individual within this State.”

In the context of professional football, following the reasoning provided in Pro-Football, Inc. v. Tupa, 197 Md. App. 463 (2011) and Pro-Football, Inc. v. McCants, 428 Md. 270 (2012), a professional football player who has not physically completed any of his job duties in Maryland may nevertheless be a covered employee because he expected to be “regularly employed” in Maryland as a professional football player.

Circuit Court for Prince George’s County Case No. C-16-CV-24-002437

REPORTED

IN THE APPELLATE COURT

OF MARYLAND

No. 549

September Term, 2025

IN THE MATTER OF CURTIS BROOKS

Berger,

Tang,

Kenney, James A., III

(Senior Judge, Specially Assigned),

JJ.

Opinion by Berger, J.

Filed: August 26, 2026

* Ripken, J. did not participate in the Court’s decision to designate this opinion for publication pursuant to Md. Rule 8-605.1.

Pursuant to the Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State Government Article) this document is authentic.

2026.08.26

'00'04- 14:32:38

Gregory Hilton, Clerk

This case arises following the denial of a workers’ compensation claim filed by Curtis Brooks (“Mr. Brooks”), appellee, against Pro-Football, LLC t/a the Washington Commanders1 (“Appellant”). Mr. Brooks is a professional football player who was hired by Appellant on August 3, 2023. On August 6, 2023, Mr. Brooks ruptured his left Achilles tendon during a training camp practice. Mr. Brooks filed a workers’ compensation claim with the Maryland Workers’ Compensation Commission (“MWCC”) on March 7, 2024. The MWCC disallowed the claim, finding that Mr. Brooks was not a covered employee in Maryland. Mr. Brooks appealed, and the Circuit Court for Prince George’s County reversed the decision of the MWCC, finding that Mr. Brooks was a covered employee. This appeal followed.

QUESTIONS PRESENTED

Appellant presents one question for our review, which we have recast and rephrased as follows:2

Whether the circuit court erred in determining that Mr. Brooks was a “covered employee” in Maryland.

For the following reasons, we affirm the judgment of the Circuit Court for Prince George’s County.

1 The record below indicates that the employer’s name is “Washington Football, Inc.” The proper employer is “Pro-Football, LLC, t/a the Washington Commanders.”

2 Appellant phrased the question as follows:

Whether the Circuit Court for Prince George’s County erred in finding that the Claimant was a “covered employee” in Maryland under Maryland Code Ann., LABOR & EMPLOYMENT § 9-203.

BACKGROUND

Appellant, Pro-Football, LLC t/a the Washington Commanders (“the Commanders”

or “the Team”), is a professional football team in the National Football League (“NFL”). Pro-Football, LLC owns and operates the Washington Commanders football team.3 The Commanders play home football games at Northwest Stadium (formerly known as FedEx Field) in Landover, Maryland. During the NFL’s 18-week regular season, each NFL team plays 17 games and has one bye week. Prior to the start of the season, each team also plays three preseason games. Over the course of preseason and the regular season, each team plays a total of ten games at home and ten games away. The Team conducts preseason training camp and regular season practice and training at facilities located in Ashburn, Virginia.

When a player is hired by an NFL team, he is required to sign the standard NFL Player Contract.4 Although each team may begin the preseason training camp with up to 90 players, before the regular season begins, each team must cut down to a maximum of 53 players on the active roster who will be called upon to play in games. Cuts may be made at any time during preseason training. Any players who are cut have their NFL Player Contract terminated. Some of the players who are cut may instead be assigned to the team’s practice squad, at which point the player signs a distinct Practice Player Contract.

3 Notably, Pro-Football, LLC t/a the Washington Commanders is a Maryland limited liability company.

Appellant notes that this is the only contract allowable at this point of the NFL 4

League Year pursuant to the NFL Collective Bargaining Agreement.

Curtis Brooks played as a defensive tackle for the University of Cincinnati football team until 2021. Mr. Brooks was selected by the Indianapolis Colts in the sixth of seven rounds of the 2022 NFL Draft. He was transferred to the Colts’ practice squad and was ultimately released by the Colts in December 2022. Mr. Brooks was signed to the Tennessee Titans practice squad in January 2023, and then signed the standard NFL Player Contract with the Titans for the 2023 NFL season. Mr. Brooks was cut from the Titans in July 2023 during preseason training.

Mr. Brooks signed the standard NFL Player Contract with the Commanders on August 3, 2023 at the training facility in Ashburn, Virginia. The terms provided that “this contract covers 1 football season(s), and will begin on the date of execution, and end on the last day of the 2023 League Year, unless extended, terminated, or renewed as specified elsewhere in this contract.” The contract further provided:

Club [Appellant] employs Player [Mr. Brooks] as a skilled football player. Player accepts such employment. He agrees to give his best efforts and loyalty to the Club, and to conduct himself on and off the field with appropriate recognition of the fact that the success of professional football depends largely on public respect for and approval of those associated with the game. Player will report promptly for and participate fully in Club’s official mandatory minicamp(s), official preseason training camp, all Club meetings and practice sessions, and all preseason, regular season and postseason football games scheduled for or by Club.

The contract additionally provided provisions pertaining to injury and workers’

compensation:

INJURY. Unless this contract specifically provides otherwise, if Player is injured in the performance of his services under this contract and promptly reports such injury to the Club physician

or trainer, then Player will receive such medical and hospital care during the term of this contract as the Club physician may deem necessary, and will continue to receive his yearly salary for so long, during the season of injury only and for no subsequent period covered by this contract, as Player is physically unable to perform the services required of him by this contract because of such injury. If Player’s injury in the performance of his services under this contract results in his death, the unpaid balance of his yearly salary for the season of injury will be paid to his stated beneficiary, or in the absence of a stated beneficiary, to his estate.

WORKERS’ COMPENSATION. Any compensation paid to Player under this contract or under any collective bargaining agreement in existence during the term of this contract for a period during which he is entitled to workers’ compensation benefits by reason of temporary total, permanent total, temporary partial, or permanent partial disability will be deemed an advance payment of workers’ compensation benefits due Player, and Club will be entitled to be reimbursed the amount of such payment out of any award of workers’

compensation.

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