NFL Players Concussion Injury Litigation v.

CourtCourt of Appeals for the Third Circuit
DecidedFebruary 20, 2025
Docket23-1585
StatusUnpublished

This text of NFL Players Concussion Injury Litigation v. (NFL Players Concussion Injury Litigation v.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
NFL Players Concussion Injury Litigation v., (3d Cir. 2025).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ____________

No. 23-1585 ____________

IN RE: NATIONAL FOOTBALL LEAGUE PLAYERS CONCUSSION INJURY LITIGATION

YVONNE SAGAPOLUTELE; MARGRIT DYKO; ANDRE HOWARD; DONNA MARTIN; RHONDA DUNCAN; LENORE STEHOUWER; NINA HUNTER; HOLLY OLIVER; MINDY STUBBS; GARY SCHUH; RONA TAYLOR; LISA CHAMBERLIN; GWENDOLYN DANIELS; WANDA CAYOLLE-PAYNE; JOHN H. BAKER, III; ELLEN MORIN; SEXTON HOLMES; AND ELLA MCGILL,

Appellants

____________

On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. Civil No. 2:12-md-02323) District Judge: Honorable Anita B. Brody ____________

Argued on January 17, 2025

Before: PHIPPS, FREEMAN, and CHUNG, Circuit Judges

(Opinion filed: February 20, 2025) David J. Campbell [ARGUED] Thompson & Horton 8300 N. MoPac Expressway Suite 220 Austin, TX 78759 Counsel for Appellants

Lynn B. Bayard Bruce A. Birenboim Brad S. Karp Kannon K. Shanmugam [ARGUED] Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas New York, NY 10019 Counsel for Appellees

_______________

OPINION* _______________

FREEMAN, Circuit Judge.

The representative claimants of eighteen retired NFL players sought compensation

under the NFL Concussion Settlement Agreement. They asserted that the retired players

had been diagnosed with Death with Chronic Traumatic Encephalopathy (“Death with

CTE”). The Claims Administrator denied their claims, the Special Master affirmed that

decision, and the District Court denied the claimants’ objections. We will affirm the

District Court’s order.

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent.

2 I1

Under the approved final Settlement Agreement for this class action, retired NFL

players or their representative claimants may receive compensation if the retired players

have certain qualifying diagnoses. See In re Nat’l Football League Players Concussion

Inj. Litig., 821 F.3d 410, 423–24 (3d Cir. 2016) (“NFL 2016”). One such diagnosis is

Death with CTE. The Settlement Agreement describes this as “a post-mortem diagnosis

of CTE made by a board-certified neuropathologist.” App. 1835.

In February 2019, eighteen representative claimants sought compensation based

on diagnoses of Death with CTE. The claimants filed materially identical two-page

letters from a board-certified neuropathologist, Dr. Ronald Hamilton. The letters were

undated. In each letter, Dr. Hamilton stated the number of seasons the retired player had

played in the NFL, provided a summary of CTE research, and opined “that it is more

likely than not” that the retired player had CTE on his date of death. App. 2453–54. Dr.

Hamilton did not examine the retired players’ brain tissue to render these diagnoses.

The Claims Administrator denied each claim for lack of evidence that Dr.

Hamilton conducted a brain-tissue examination to confirm his CTE diagnosis. The

claimants appealed to the Special Master, who affirmed the denials because of the lack of

1 Because we write primarily for the parties, we recite only the facts necessary to our decision.

3 brain-tissue examinations.2 The claimants objected to the Special Master’s rulings, and

the District Court denied the objections in a summary order.

The District Court later issued an explanation for its ruling. It relied on two

sources of information to conclude that Death with CTE can be properly diagnosed only

after a review of brain tissue. First, it looked to the language of the Settlement

Agreement. It addressed two terms: “neuropathologist” and “post-mortem.” It noted that

a neuropathologist is a doctor who specializes in studying cells and tissue samples under

a microscope, and a neuropathologist can only examine a retired player’s brain tissue

after the player’s death. Second, it looked to two prior judicial opinions addressing the

Settlement Agreement. Both opinions addressed the science underlying a Death with

CTE diagnosis. In the District Court’s 2015 opinion granting final approval to the

Settlement Agreement, it wrote that “no one can conclusively say that someone had CTE

until a scientist looks at sections of that person’s brain under a microscope to see if

abnormally phosphorylated tau protein . . . is present, and if so whether it is present in a

reportedly unique pattern.” In re Nat’l Football League Players Concussion Inj. Litig.,

307 F.R.D. 351, 397 (E.D. Pa. 2015). And in this Court’s 2016 opinion affirming the

final approval, we made similar observations. See NFL 2016, 821 F.3d at 421–22 (noting

that “CTE involves the build-up of ‘tau protein’ in the brain”; that “it is only diagnosable

post-mortem”; and that “diagnosis requires examining sections of a person’s brain under

2 The Special Master also affirmed the Claims Administrator’s denial of the claims on a second ground: that the claims were untimely. The District Court did not reach that issue, and the claimants did not address it their appeal to us.

4 a microscope to see if abnormal tau proteins are present and, if so, whether they occur in

the unique pattern associated with CTE”). Based on all this, the District Court concluded

that the claims were properly denied for lack of brain-tissue examinations.

The claimants timely appealed.

II3

The Settlement Agreement is a contract subject to the principles of contract

interpretation. Rainbow v. Swisher, 527 N.E.2d 258, 259 (N.Y. 1988); App. 1820

(selecting New York state law to govern the interpretation of the Settlement Agreement).

When a contract is “clear, complete and subject to only one reasonable interpretation”

(i.e., when the contract is unambiguous), it must be enforced according to the plain

meaning of its language without reference to extrinsic evidence. Brad H. v. City of New

York, 951 N.E.2d 743, 746 (N.Y. 2011); Rainbow, 527 N.E.2d at 259. However, when a

contract is susceptible to more than one reasonable interpretation (i.e., when the contract

is ambiguous), courts may consider extrinsic evidence. Brad H., 951 N.E.2d at 746.

3 The District Court had jurisdiction under 28 U.S.C. § 1332(d). We have jurisdiction under 28 U.S.C. § 1291. We review the District Court’s interpretation of the Settlement Agreement’s terms for clear error, and we apply plenary review to its construction of the Settlement Agreement. Nat’l Football League Players’ Concussion Inj. Litig., 923 F.3d 96, 107 n.8 (3d Cir. 2019). Under the clear error standard, we will not interfere with the District Court’s decision unless, after reviewing the evidence, we are “left with a definite and firm conviction that a mistake has been committed.” In re Cendant Corp. Prides Litig., 233 F.3d 188, 193 (3d Cir. 2000) (quoting United States v.

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