John P. Askin v. University of Notre Dame

CourtCourt of Appeals of Kentucky
DecidedJuly 27, 2023
Docket2022 CA 000775
StatusUnknown

This text of John P. Askin v. University of Notre Dame (John P. Askin v. University of Notre Dame) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John P. Askin v. University of Notre Dame, (Ky. Ct. App. 2023).

Opinion

RENDERED: JULY 28, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2022-CA-0775-MR

JOHN P. ASKIN APPELLANT

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE ANGELA MCCORMICK BISIG, JUDGE ACTION NO. 19-CI-001063

UNIVERSITY OF NOTRE DAME APPELLEE

OPINION AFFIRMING AND ORDER DENYING MOTION TO DISMISS

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; KAREM AND MCNEILL, JUDGES.

KAREM, JUDGE: John P. Askin appeals from the Jefferson Circuit Court’s

granting of summary judgment to the University of Notre Dame du Lac (“Notre

Dame”) and its dismissal with prejudice of his complaint against the University.

Askin suffers from a brain disease, chronic traumatic encephalopathy (“CTE”),

which he contends is the result of multiple concussions he suffered while playing football for Notre Dame as a student athlete in the 1980s. He brought a personal

injury suit against Notre Dame and the National Collegiate Athletics Association

(“NCAA”). The circuit court granted summary judgment to Notre Dame on statute

of limitations grounds and denied it to the NCAA. Having carefully reviewed the

record, we affirm the grant of summary judgment to Notre Dame.

Notre Dame has moved to dismiss this appeal on the grounds that the

NCAA was not named as a party. The motion is denied because Notre Dame has

failed to show it has standing to make this motion on behalf of the NCAA.

Factual and Procedural Background

Askin was an offensive lineman for the Notre Dame football team

from 1982 to 1986. During that time, he suffered numerous concussions at

practices and games. In his deposition testimony, Askin recalled suffering mild

concussions on a weekly basis. He also suffered more serious concussions. On

one occasion, which is documented in Notre Dame’s medical records, he was

knocked unconscious and sent to the hospital for a CT brain scan. He returned to

practice several hours later that day at the insistence of the coach.

After leaving Notre Dame, Askin signed short NFL contracts with the

Cleveland Browns and the New England Patriots. He suffered a back injury and a

knee injury, which ended his professional career. He went on to work as a regional

manager for an insurance company and then for BB&T Bank in Louisville.

-2- Over time, Askin, who suffers from rheumatoid arthritis, experienced

increasing orthopedic pain and joint instability. In 2009, when he was forty-five

years of age, his deteriorating physical condition caused him to resign his position

at BB&T Bank. He qualified for Social Security disability benefits for orthopedic

injuries and received additional benefits through his employer’s policy issued by

The Hartford Insurance Company.

In 2012, Askin began treatment with Dr. Darel Barnett, a pain

management physician. According to Dr. Barnett’s notes from an office visit on

January 9, 2013, Askin “relates his low back, neck pain and headache pain to

trauma from playing football.”

Dr. Barnett prescribed MS Contin (morphine) and oxycodone. By

2013 and 2014, Askin was experiencing headaches and cognitive problems,

including short-term memory loss. He had difficulty remembering names and

performing everyday activities. According to Askin, he became addicted to opiates

while in Dr. Barnett’s care, and his addiction was responsible for causing these

symptoms.

At around this time, Askin began to receive correspondence regarding

the NFL concussion settlement. From these mailings, as well as extensive media

coverage of the negotiations, he became aware that there was an alleged link

between football-related head injuries and long-term cognitive problems. He

-3- turned over solicitations from attorneys about the concussion litigation to his own

attorney. He also began to receive daily phone calls on the subject from various

law firms.

Of particular significance to this lawsuit are the interactions between

Askin and Oliver Olson, APRN, his pain management nurse. At a regular office

visit on September 24, 2014, Olson’s discussion summary stated in part as follows:

He [Askin] reports problems with memory noting that his wife often will become frustrated that she has asked him to do a task or told him something specific that requires repeated reinforcement. I discussed with him about compensation/litigation with NFL. He reports that he is required to obtain brain scan by October. I discussed with him the rationale why this is important and encouraged him to get this done in a timely manner. Our office will provide support and help in any capacity possible.

Olson also noted, “I have encouraged the patient to continue litigation for former

NFL players.”

On October 10, 2014, Askin saw Olson again and reported that he was

experiencing tremors in his left hand and whole body tremors while sleeping.

During this visit with Olson, Askin filled out an insurance questionnaire for The

Hartford for purposes of retaining his disability insurance. The questionnaire

contained the following question: “Have you suffered a severe Cognitive

Impairment that renders you unable to perform common tasks, such as using the

phone, money management or medication management?” Askin checked the “yes”

-4- box and wrote: “Concussions in football – College & NFL[;] memory going.”

Although Askin acknowledges writing this response, he claims Olson told him

how to fill out the form to ensure he continued receiving insurance coverage and

because Askin was under the influence of morphine and oxycodone at that time.

He testified that he has no recollection of completing the form.

Olson filled out an accompanying form for The Hartford, which Askin

also signed, entitled “Attending Physician’s Statement of Continued Disability” in

which he checked the “yes” box for the question asking, “Does the patient have a

psychiatric/cognitive impairment?” He wrote that Askin showed “early signs of

chronic traumatic encephalopathy[;] mild impairment at this point. Evaluation

pending. Etiology: retired NFL football player, lineman.” Olson testified that he

believed Askin should be considered for the NFL settlement and that Askin had

shown him a mailing from the NFL which required him to undergo a neurological

evaluation in order to be considered for the settlement. Olson explained that in

filling out the form he was not providing a diagnosis, that he had not performed

any kind of extensive evaluation and he would not have spoken to Askin about

brain damage. He also opined that checking the box “yes” was likely premature,

which was why he included the phrase “evaluation pending” on the form.

Meanwhile, Askin grew concerned about the effects of his opioid use

and feared that his addiction would kill him. His friends and family were also

-5- alarmed by his opioid use and its effect on him. His wife testified that it made him

very irrational and unstable; a friend testified that his speech was slurred, and he

had difficulty conducting a coherent conversation; another friend observed he

seemed heavily medicated.

Around 2015, Askin stopped taking opioids and overcame his

addiction. As a result, Dr. Barnett discharged him as a patient and also discharged

Nurse Olson. Askin began to pursue a medical malpractice action against Dr.

Barnett. Askin’s friends observed him return to his former self, describing him as

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