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Keywords

appealworkers' compensation
appealworkers' compensation

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Pro-Football, Inc. v. McCants, 428 Md. 270, 51 A.3d 586

Facts

Darnerien McCants, a professional football player for the Washington Redskins, filed six claims for workers' compensation after sustaining injuries during games. The Maryland Workers' Compensation Commission denied five claims, asserting he was not a 'covered employee' under the law. McCants appealed, and the Circuit Court affirmed the Commission's decision. However, the Court of Special Appeals reversed, determining that McCants was indeed a 'covered employee' as he was regularly employed in Maryland while playing for the team.

Issue

Whether a football player employed by the Washington Redskins is a 'covered employee' under Maryland's workers' compensation laws when injured while practicing and playing football outside of Maryland.

Whether a football player employed by the Washington Redskins is a 'covered employee' under Maryland's workers' compensation laws when injured while practicing and playing football outside of Maryland.

Rule

To qualify as a 'covered employee' under Maryland's Workers' Compensation Act, an individual must be employed by the employer and the employment must occur within the state. An individual working outside the state may still be considered a 'covered employee' if they are regularly employed within the state and their work outside is casual, incidental, or occasional.

To qualify as a 'covered employee' under Maryland's Workers' Compensation Act, an individual must be employed by the employer and the employment must occur within the state. An individual working outside the state may still be considered a 'covered employee' if they are regularly employed within the state and their work outside is casual, incidental, or occasional.

Analysis

The court analyzed whether McCants was regularly employed in Maryland despite spending significant time practicing in Virginia. The court noted that the essence of McCants' employment was to play in games, most of which occurred in Maryland. The court concluded that his practice time in Virginia was incidental to his primary role of playing in games, thus qualifying him as a 'covered employee' under the law.

The court analyzed whether McCants was regularly employed in Maryland despite spending significant time practicing in Virginia. The court noted that the essence of McCants' employment was to play in games, most of which occurred in Maryland. The court concluded that his practice time in Virginia was incidental to his primary role of playing in games, thus qualifying him as a 'covered employee' under the law.

Conclusion

The Court of Appeals affirmed the decision of the Court of Special Appeals, holding that McCants was a 'covered employee' under Maryland law, allowing him to pursue his claims for workers' compensation.

The Court of Appeals affirmed the decision of the Court of Special Appeals, holding that McCants was a 'covered employee' under Maryland law, allowing him to pursue his claims for workers' compensation.

Who won?

Darnerien McCants prevailed in this case as the court determined he was a 'covered employee' under Maryland's Workers' Compensation Act. The court emphasized that the nature of his employment was defined by the games he played, most of which occurred in Maryland, and that his practice time in Virginia was merely incidental to his primary employment duties.

Darnerien McCants prevailed in this case as the court determined he was a 'covered employee' under Maryland's Workers' Compensation Act. The court emphasized that the nature of his employment was defined by the games he played, most of which occurred in Maryland, and that his practice time in Virginia was merely incidental to his primary employment duties.

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