No-Duty Rule Applied to Football Related Head Injury Claims

In the case of Schretzman v. NCAA, Nol 2883 EDA 2024 (Pa. Super. Sept. 16, 2026 Lane, J.) (Op. by Lane, J.), the court applied the no-duty negligence rule under Pennsylvania law to a claim by a Plaintiff alleging injuries from repeated football-related head injuries.

According to the Opinion, the Plaintiff was a former member of the West Point College football team. He was diagnosed with ALS.

The Plaintiff sued the NCAA under an allegation that the NCAA allegedly failed to warn him of the risks associated with repeated football-related head injuries.

The Superior Court affirmed the trial court’s entry of the NCAA’s Motion for a Compulsory Nonsuit.

The Superior Court noted that it was “bound under Pennsylvania’s no-duty negligence rule to hold the NCAA did not owe a duty of care to warn college player that repeated head injuries, in the support of football, may cause, decades later, latent neurogenerative disease, including [ALS].”

Anyone wishing to review a copy of this decision may click this LINK.


Source: The Pa. Super. Blog by Jon Bruno of Bruno Litigation, LLC, in Pittsburgh, PA.