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contractstatuteappealwillworkers' compensationappellant
contractworkers' compensationsustainedappellant

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Rudolph v. Miami Dolphins, Ltd., 447 So.2d 284

Facts

Three professional football players, Council Rudolph, William Windauer, and Floyd Wells, appealed from orders denying them worker's compensation benefits after sustaining injuries during training camp with the Miami Dolphins. Each player was under contract with the Dolphins and was receiving compensation at the time of their injuries. The deputy commissioners denied their claims based on the statutory exclusion of professional athletes from worker's compensation coverage under Florida law. The players contended that they were not engaged as professional athletes at the time of their injuries and that the Dolphins had waived the exclusion.

Each appellant was under contract with the Miami Dolphins, Ltd., pursuant to a National Football League Players contract and a collective bargaining agreement between club members of the National Football League and player members of the NFL Players Association. Appellants sustained injuries while in training camp prior to the beginning of the regular football season, and each was subsequently terminated by the Dolphins.

Issue

Did the deputy commissioners err in finding that the appellants were not entitled to benefits under the Florida Workers' Compensation Act?

Whether the deputy commissioners erred in finding that appellants were not entitled to benefits under the Florida Workers' Compensation Act.

Rule

The Florida Workers' Compensation Act excludes professional athletes from coverage, as defined in section 440.02(1)(c)3, which states that 'employment' does not include 'service performed by or as a professional athlete.' This exclusion applies whenever an athlete is injured while performing activities related to their employment, including training and competition, regardless of whether they have made the team roster.

Section 440.02(1)(c)3 provides, for purposes of coverage under the act, that the term 'employment' does not include 'service performed by or as a professional athlete' such as a 'football player.'

Analysis

The court analyzed the statutory exclusion and determined that each appellant was engaged in activities as professional athletes at the time of their injuries, as they were under contract and receiving compensation. The court rejected the argument that the exclusion only applied once a player made the team roster, affirming that the exclusion is applicable during all training and competition activities required by their contracts.

We do not believe the statutory exclusion of professional athletes becomes applicable only when persons are playing during the regularly scheduled football season after making the team roster. The exclusion becomes operative whenever a professional athlete is injured incident to performing the contemplated activities of his employment as a professional athlete, whether during pre-season camp, during regular season practice, or during a regularly scheduled game.

Conclusion

The court affirmed the deputy commissioners' orders denying worker's compensation benefits to the appellants, concluding that they were excluded from coverage as professional athletes under Florida law.

Finding no reversible error in the three orders dismissing appellants' claims for worker's compensation benefits, they are AFFIRMED.

Who won?

The Miami Dolphins prevailed in this case as the court upheld the deputy commissioners' decisions denying the players' claims for worker's compensation benefits. The court found that the statutory exclusion for professional athletes was applicable to the appellants, who were engaged in activities related to their employment at the time of their injuries. The Dolphins had not waived this exclusion, and the players' contractual rights did not extend to enforceable worker's compensation benefits under the statute.

The Miami Dolphins qualified as a self-insured employer under the Florida Workers' Compensation Act and had not waived the professional athlete exclusion in section 440.02. The court found that the players were engaged in activities as professional athletes at the time of their injuries, thus affirming the denial of their claims for benefits.

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