Sara Allen
Edited by Atreyee "Jiya" Ghosh, Sahith Mochalra, and Roohie Sheikh
It’s early January 2022. The New York Jets are hosting the Tampa Bay Buccaneers. The score is 24-10 Buccaneers with 2:58 left in the third quarter. The Buccaneers face 3rd & 7, yet no one can focus on the game. All eyes are drawn to Tampa Bay wide receiver Antonio Brown, one of the most talented receivers of his generation, who had just taken off his pads, jumped and waved at the crowd, and sprinted off into the locker room without explanation. Bewildered fans exchange confused glances–what was he doing?
According to a statement released by Brown about the incident, an MRI the following Monday revealed extensive structural damage to his ankle. This statement indicated that his refusal to play stemmed from pain caused by his injury and simultaneously accused the Buccaneers of “mischaracterizing his outburst as a mental health issue” while pressuring him to play through pain; however, the Buccaneers’ coaching staff and medical personnel denied prior knowledge of Brown’s injury [1]. Brown was released from the team soon after that, marking a puzzling, abrupt, and unofficial end to Brown’s controversial National Football League (NFL) career.
For years, Brown had been regarded as one of his era's most talented wide receivers and one of the NFL’s most polarizing players. A seven-time Pro Bowl selection and former Pittsburgh Steelers standout, his career was impressive, yet overshadowed by a string of off-the-field controversies—including sexual misconduct allegations, a public dispute with the Oakland Raiders over a helmet, and bizarre social media antics. Combined with his erratic behavior, like live-streaming conversations in the Steelers locker room and walking out of practice, he painted a portrait of a player as unpredictable as he was talented. In the eyes of many, Brown was just another primadonna wide receiver whose legacy was marred by this antagonistic behavior, personal scandals, and legal disputes. Yet, some speculated that his unusual behavior may stem from repeated head trauma sustained throughout his career.
One of the darkest undercurrents of America’s most popular sport is its physical toll on the sport’s beloved athletes. Chronic Traumatic Encephalopathy (CTE)–a degenerative brain disease linked to repetitive head trauma–epitomizes football’s hidden dangers [2]. The NFL has long been criticized for its inadequate responses to these risks, and high-profile incidents and subsequent litigation have often shaped the league’s attempts to navigate its responsibilities. In his retirement, Brown has maintained an online presence in the world of professional sports –his merchandising campaign and social media hashtag, CTESPN, makes fun of the medical term but underlies a bitter truth: the long-term consequences of football are deeply personal and poorly addressed. While CTE can only be diagnosed posthumously, Brown’s struggles highlight the NFL’s broader systemic failure to address the long-term health consequences of football.
Despite the NFL’s implementation of safety measures in recent years, its history of litigation reveals that these changes are often driven by external pressures rather than legitimate internal concern for the welfare of its players.
A History of CTE
The scientific link between repetitive head trauma and CTE is now widely recognized. Common symptoms include behavioral problems, mood problems, and cognitive decline–later progressing into dementia [3]. Concussions and repeated game-related head blows have been linked to the development of CTE, as it has been found in 345 of 376 deceased former NFL players, according to a 2023 report by the Boston University CTE Center [4]. According to a 2017 study on the brains of deceased American football players, 99% of tested brains of NFL players, 88% of Canadian Football League (CFL) players, 64% of semi-professional players, 91% of college football players, and 21% of high school football players had various stages of CTE [5]. The connection is clear, but for decades, the NFL has downplayed and sometimes actively denied the risks associated with concussions and head injuries. This denial laid the groundwork for numerous lawsuits from former players, whose lives were tarnished by the neurodegenerative long-term effects of football-related injuries.
The NFL largely sidelined the issue of in-game concussions until 1994, when then NFL Commissioner Paul Tagliabue approved the creation of the Mild Traumatic Brain Injury (MTBI) Committee. Tagliabue appointed the New York Jets team doctor and rheumatologist–joints, muscles, and bones doctor–Dr. Elliot Pellman, as chair, despite his lack of experience in neuroscience or brain trauma. When asked about concussions in the NFL, Pellman told Newsday, “We discuss it on the list of things every time we have a league meeting... we think the issue of knees, of drugs and steroids, and drinking is a far greater problem, according to the number of incidents” [6].
Despite these comments, an increasing number of NFL players were experiencing violent, high-profile head injuries. Dallas Cowboys quarterback Troy Aikman took a knee to the head during the 1993 season NFC Championship game. Unable to finish the game, he told the Milwaukee Journal Sentinel, “I didn’t know what planet I was on. I still to this day have no recollection of ever having played in that game. So whenever I see footage of that game, it’s like somebody else is out there doing it” [7]. Aikman believes he suffered from at least a half-dozen concussions during his 12-year career. By December 1994, Paul Tagliabue dismissed the problem of concussions entirely, describing them as a “journalist issue,” as opposed to a real issue [8]. These words, when repeated back to the league in lawsuits, would come to haunt them.
In 1998, the beloved 14-year Pittsburgh Steelers center, nine-time Pro Bowler, Hall of Famer, and four-time Super Bowl champion Mike Webster claimed that repeated, low-grade blows to his head during his NFL career gave him dementia. When Webster died in 2002 at the age of 50, an autopsy revealed he suffered from CTE from his 15 years in the NFL–a condition that, until this point, was only believed to be found in boxers [9]. Before his death, the NFL Retirement Board ruled that Mike Webster’s head injuries from playing football left him “totally and permanently” disabled, while the NFL simultaneously denied linkage between concussions and long-term brain injuries [10]. Webster’s attorney, Bob Fitzsimmons, said the ruling showed that the NFL should have known the link between football and brain damage: “If the NFL takes the position that they didn’t know or weren’t armed with evidence that concussions can cause total disability–permanent disability, permanent brain injury–in 1999, that evidence trumps anything they say” [11]. The NFL still largely ignored the issue of CTE until 2009 when Cincinnati Bengals wide receiver Chris Henry was diagnosed with CTE after his death at age 26. The discovery of Henry’s CTE was alarming–Henry had never been reported to have any concussions throughout his entire NFL and collegiate career. Not only had the NFL obstructed the links between concussions and long-term brain damage, but new research indicated that an accumulation of lesser blows–not just concussions–can also result in the significant deterioration of brain health. The brain damage Henry suffered may have been a contributing factor in his numerous off-the-field legal issues [12]. Why then, did the NFL not face greater scrutiny or accountability for its role in downplaying the risks of repetitive head trauma and delaying meaningful reforms to protect players? The answer lies in a deflection of blame, the convoluted legal stipulations of collective bargaining agreements, and the repeated prioritization of profit over player welfare.
Accountability & Collective Bargaining Agreements (CBA)
Long before awareness of CTE had risen to national prominence, Korey Stringer, a 27-year-old offensive tackle for the Minnesota Vikings, suffered a fatal heat stroke during training camp before the 2001 football season. After his death, Stringer’s estate–led by his wife–filed a negligence and wrongful death lawsuit against the NFL, arguing that the NFL failed to provide adequate policies and training regarding heat-induced illness prevention. It also claimed the league had a duty to protect players from hazardous conditions, including the episode of extreme summer heat in Minnesota in 2001, yet failed to ensure that proper medical practices were followed at the Minnesota Vikings’ training camp [13]. The court ruled that Stringer’s claims were preempted by the collective bargaining agreement (CBA) between the NFL (employer) and the NFL Players Association–the players, represented by their union (NFLPA)–concluding that the resolution of the lawsuit would require interpretation of the CBA, which governed the working conditions and safety protocols [14].
In the Stringer case, the NFL argued–and the court agreed–that the estate’s negligence and wrongful death claims were linked with the working conditions language outlined in the CBA [15]. The claims could not be addressed independently without consideration of the NFL’s agreements with the NFLPA about player safety. Since the CBA established the rules for athlete safety, any legal dispute about said rules fell under federal labor law as opposed to state law. Federal labor law preempts state-law claims if they require interpreting the terms of a CBA.
Reiterated, this ruling shielded the NFL from direct liability for Stringer’s death because the claims had to be addressed within the mechanics of the CBA, limiting Stringer’s estate to sue under state tort law (i.e., the foundation of the estate’s wrongful death lawsuit was grounded in Minnesota law) [16]. With that being said, Stringer’s case raised awareness of occupational hazards in professional sports and prompted changes to heat safety protocols within the NFL–the NFL agreed to support efforts for a heat illness prevention program [17].
While the Stringer case dealt with heat-related protocols, the important aspect of this lawsuit relating to CTE litigation pertains to the utility of the CBA to limit the NFL’s legal liability. Many former players’ lawsuits against the NFL for failing to adequately address concussion risk and CTE have similarly been preempted or settled under the terms of the CBA, with the NFL successfully arguing that health management protocols fall under the league’s negotiated labor agreements. The Stringer case set a precedent for how the NFL could use its labor agreements to avoid broader legal accountability for player safety rather than proactive safety measures, making it difficult to hold the league accountable for long-term health issues, including CTE.
Withholding the Truth
In Dent v. NFL, a class-action lawsuit was filed by eight retired NFL players alleging negligence by the NFL regarding the handling and distribution of pain management drugs. The plaintiffs claim that between 1969 and 2014, the NFL facilitated widespread, improper administration of controlled substances to players–enabling them to return to games prematurely in violation of federal and state laws, namely the Controlled Substances Act and the Food, Drug, and Cosmetic Act (FDCA) [18]. The actions of the NFL were alleged to have prioritized profits over player safety, endangering their health. The Controlled Substances Act governs controlled substances' manufacture, distribution, and use. The plaintiffs alleged that the NFL defied the law through improper recordkeeping, unauthorized distribution, lack of prescriptions, and the facilitation of drug misuse. In other words, the NFL failed to document the distribution of controlled substances as legally required, allowed unauthorized personnel to administer medications (i.e., trainers instead of licensed physicians), distributed controlled substances without prescriptions, and created an environment where players were coerced into using medications without informed consent or proper medical oversight. The plaintiffs also alleged the misbranding of drugs, failure to ensure safeguards for the proper use of drugs, and the neglect of proper storage and handling, all in violation of the FDCA [19].
The lawsuit, initiated in 2014, has seen multiple appeals and dismissals; the plaintiffs argued that the NFL had a duty of care regarding the distribution of medications and breached that duty through negligence, voluntary undertakings, and creating hazardous playing environments. The court ruled that the players' state law claims are preempted by section 301 of the Labor Management Relations Act (LMRA). The applicable aspect of Section 301 is the concept of “preemption,” where state law claims that are dependent on the interpretation of a CBA may be superseded by federal law [20]. Again the NFL was largely shielded from liability in this case–why is that?
The answer lies, yet again, in the CBA. Any indirect activity on player welfare is governed by the CBA; therefore, any player grievances should be handled within the parameters laid out by that document. The players forfeited their ability to use the courts when they agreed to the terms of the CBA [21]. Secondly, the courts held that individual franchises are responsible for any medical care that players receive, not the league itself. Cases like Stringer and Dent outline the propensity for the CBA to shield the NFL from liability in player safety, a process observed in CTE litigation.
Consequences of a Legacy of Negligence
Despite the precedent established in previous cases, the NFL has long been embroiled in legal controversies surrounding CTE and player safety. In 2013, the league reached a landmark $765 million settlement with thousands of former players who accused it of concealing the risks of concussions [22]. Critics argue that the settlement failed to hold the league fully accountable–it included no admission of liability and capped damages for players suffering from CTE-related conditions.
For example, two important cases that later became a part of the NFL’s consolidated concussion litigation highlight the heart of the issue: inadequate medical support for former athletes and failure to provide informed consent for current athletes on the dangers of long-term brain injury. Easterling vs. NFL highlighted the case of Ray Easterling, a former Safety for the Atlanta Falcons who died from a self-inflicted gunshot wound to the head at the age of 72 in 2012, after dealing with dementia and depression in his retirement. Easterling never sought confirmation that his cognitive issues were related to head trauma, but an autopsy revealed evidence of moderately severe CTE. His wife, Mary Ann Easterling, became a prominent advocate for justice on behalf of NFL players, alleging that the league downplayed concussion risks and ignored the long-term effects of brain injuries [23]. Turner vs. NFL highlighted the case of Kevin Turner, a former NFL fullback diagnosed with Amyotrophic lateral sclerosis (ALS), a fatal neurological disorder that causes the progressive loss of motor neurons in the brain and spine. The progression of the disease leaves people without the function of their limbs and eventually stops their ability to breathe on their own. Similar to Easterling, Turner suggested that his time in the NFL led to the development of the disease due to repeated head trauma that the NFL failed to address properly. Turner became a key figure representing the human cost of the league's alleged misconduct until his death at the age of 46. After his death, an autopsy confirmed a severe case of CTE triggered the onset of ALS. His case, along with others, emphasized the NFL’s failure to disclose the long-term neurological effects of concussions [24].
A third case, Junior Seau v. NFL added another dimension to the human toll of CTE. Junior Seau, a Hall of Fame linebacker, took his own life in 2012 at the age of 43. A posthumous examination of his brain revealed severe CTE. His family filed a wrongful death lawsuit against the NFL, alleging that the league ignored evidence linking repeated head trauma to CTE and failed to warn players of the risks [25]. Seau’s death and the subsequent lawsuit highlighted the devastating mental health impact of CTE and placed significant public pressure on the NFL to reform its policies. Seau's case became a symbol of the league’s moral and systemic failure to prioritize player safety over profits, emphasizing the inadequacy of the 2013 settlement in addressing widespread issues within the league.
NFL Concussion Litigation
The consolidated NFL Concussion Litigation (2011-2013) brought the NFL’s negligence into sharper focus–over 45,000 former players accused the NFL of concealing scientific evidence linking repetitive head trauma to CTE [26]. The lawsuit designated $675 million for players or the families of players who sustained cognitive injury, $75 million to be set aside for baseline medical exams, and the creation of a $10 million research fund. However, the settlement lacked provisions for future claims and included significant loopholes for the NFL to deny liability. For example, players who died after the settlement’s approval were often excluded from compensation–leaving their families without recourse [27]. Since the settlement, the NFL has awarded $1.2 billion to more than 1,600 athletes. However, a Washington Post investigation found the league saved millions of dollars by rejecting payouts to hundreds of retired players suffering from dementia, including many who died [28].
The NFL heavily relied on the CBA to shield itself from liability during the concussion litigation. The league argued that issues related to player safety and medical care fell under the scope of the CBA, which outlines the terms of employment between players and their teams, including provisions for medical treatment and safety protocols. This framing positioned the concussion-related claims as labor disputes rather than independent legal claims, thereby requiring resolution through arbitration instead of litigation in court. In other words, the NFL held the same legal precedent used in Stringer and Dent to deflect liability for CTE.
The NFL again contended that individual franchises, not the league itself, were responsible for the medical care of players–including head injuries that progressed into CTE. The CBA establishes that team doctors and medical professionals are tasked with ensuring player health, absolving the league from liability for improper medical treatment [29]. The NFL argued that claims about negligence or failure to warn about the risks of concussions properly were preempted by federal labor laws. Under the Labor Management Relations Act (LMRA), disputes involving provisions of a CBA must be resolved through arbitration rather than in court [30]. This argument successfully limited the scope of the lawsuits, as courts often deferred to the terms of the CBA [31]. While the league ultimately agreed to the aforementioned $765 million settlement in the concussion litigation, the use of the CBA enabled it to avoid admitting liability in the settlement. This approach also helped the NFL avoid disclosing potentially damaging internal documents about what it knew regarding the risks of head injuries, preserving its public image and limiting future claims.
However, the NFL faced backlash over its use of a process called “race-norming” in the concussion settlement process. Race-norming is the practice of adjusting test scores to account for the race of the test-taker. The use of race-norming by the NFL adjusted cognitive test scores based on race, which made the threshold for Black players higher –making it more difficult for them to qualify for compensation for football-related cognitive decline. Lawyers for black athletes suspected that white men were qualifying for awards from the settlement at “two or three times the rate” of black players since the payouts began in 2017 [32]. The NFL abandoned the practice in 2021, but the controversy once again underscored systemic issues in the league’s approach to player safety and equity.
NFL Procedural Changes
Since the settlement of the concussion litigation, the NFL has made several procedural changes to limit the impact of head injuries on players. The NFL instituted a comprehensive concussion protocol that mandates immediate evaluation of players having been suspected of sustaining concussions during games. These evaluations are conducted by unaffiliated neurotrauma consultants (UNCs), who operate independently of the teams–intended to give the players a layer of protection. The updated protocol includes pre-season baseline testing for medical reference, in-game spotters to monitor for head trauma, and “no-go” symptoms, such as loss of consciousness or balance issues that immediately remove players from games [33]. While these protocols represent a step forward in ensuring player safety, critics argue that they are reactive rather than preventive, addressing injuries after they occur without addressing the cumulative nature of repetitive head trauma, as CTE has been found to develop in players without a history of concussions [34].
The NFL has also worked to improve player safety through advancements in helmet technology. Collaboration with manufacturers and engineers has led to the creation of special helmets designed to reduce the impact of collisions. These helmets, called “guardian caps,” are increasingly being utilized in practice, yet in-game use is voluntary for players [35]. All helmets are also evaluated for efficacy in the pre-season, and the banning of older models for in-game use has been put in place. However, these measures focus primarily on mitigating impacts during gameplay and do not address the long-term risks associated with repetitive subconcussive hits, which are equally implicated in CTE.
The NFL has made numerous rule changes to limit high-risk plays associated with head injuries, including targeting and helmet-to-helmet contact. The league implemented strict penalties for leading with the helmet and targeting an opponent’s head during tackles. Kickoffs, historically resulting in high-speed collisions, have been restricted to minimize the distance players cover before contact–reducing the risks of severe impact. The NFL has also limited full-contact practices during the season to reduce repetitive head trauma [36].
Toward a Framework of Accountability
Despite the changes made to policy and protocol aimed at improving the safety of players, the NFL remains on the reactive end of safety. The fact that the NFL had to be sued numerous times by players who had suffered from football-related injuries before changes were implemented speaks to the lack of accountability of the league in protecting players. Ultimately, the NFL made changes to their protocol only after denying liability in the 2013 concussion settlements, yet if they were truly exempt from all liability for the long-term brain damage of former players, alterations in the protocol should not have occurred. If the NFL instituted changes in how they handled concussions and player safety, their previous practices did not do enough to ensure the safety of their players. The NFL has never proactively researched the impact of sub-concussive and concussive head injuries, even going as far as denying the link between football and CTE as recently as the 1990s. A 2004 doctoral dissertation by Don Brady examining active and retired NFL players’ knowledge of concussions concluded that players lacked an essential and basic understanding of various aspects of a concussion [37]. While twenty years have passed since then, the question remains if the NFL adequately educates players, coaches, and families about the risks of repeated concussions–what can be done?
Ultimately, the NFL must implement transparent risk communication–players must be fully informed of the health risks associated with concussions and other injuries to make informed consent about their careers. Enhanced education programs can create a culture of accountability that could help players identify concussion symptoms, understand proper concussion management, and understand the latest research regarding long-term brain health. If players are aware of the risk of concussions, they can make decisions about their career, preparation, injury management, and future with accurate and up-to-date information. Incentivizing players to report symptoms early and ensuring that they are not pressured to play through concussion symptoms is key to the development of a proactive approach to concussion safety.
Beyond this, health evaluations should be conducted by third-party physicians, eliminating conflicts of interest inherent to team-employed medical staff. While UNCs are independent, team-employed medical staff may face implicit pressure to prioritize performance over safety. Even UNCs have been found liable for mismanaging player injuries, as was the case with Miami Dolphins Quarterback Tua Tagovailoa. Tagovalioa demonstrated symptoms of a concussion yet was cleared to return to a Sept. 2022 game against the Buffalo Bills. After the game’s conclusion, the UNC that evaluated Tagovailoa made “several mistakes” in their evaluation, failed to understand their role, and was hostile during the investigation process, resulting in their termination by the NFL Player’s Association [38].
Lastly, the NFL must establish a long-term healthcare fund to support players dealing with CTE-related health issues. This fund would ensure that players who experience long-term consequences of head injuries sustained in their tenure in the NFL receive the medical care and financial support they need in retirement. Whereas in the past the NFL has denied compensation to retired players, such a fund would reflect a commitment to their health and well-being and could help mitigate the lasting effects of concussion-related conditions.
Conclusion
While navigating the post-career future of professional athletes, particularly in the context of mental health and public behavior, it becomes increasingly clear that issues like CTE cannot be ignored as they have been in the past. As was seen with Antonio Brown, greatness can be undercut by repeated head trauma–Brown’s tumultuous career is a startling example of the growing concern for former athletes. His public outburst and other off-the-field incidents may be a source of comedic relief, but the underlying threat of dementia, ALS, and serious neurodegeneration could lie ahead.
As more research emerges about CTE and its impact on football players, the conversation must evolve from focusing on individual actions to including systemic issues within the NFL. The league’s failure to adequately address the risks of concussions and brain injuries in football has led to tragic outcomes for many athletes, with much of the recent reform still resorting to reactionary measures and deflection of blame. The NFL must confront the realities of CTE, ensure better prevention, and offer appropriate support for players facing the consequences of brain injuries.
[1] AB: Bucs tried to force me to play through injury, ESPN.com (2022), https://www.espn.com/nfl/story/_/id/33002723/antonio-brown-releases-lengthy-statement-tells-side-story-days-leaving-tampa-bay-buccaneers-game (last visited Dec 9, 2024).
[2]What is CTE? | Traumatic Brain Injury | IU School of Medicine, https://medicine.iu.edu/expertise/traumatic-brain-injury/what-is-chronic-traumatic-encephalopathy (last visited Dec 1, 2024).
[3] Asken BM, Sullan MJ, DeKosky ST, Jaffee MS, Bauer RM. Research Gaps and Controversies in Chronic Traumatic Encephalopathy: A Review. JAMA Neurol. 2017;74(10):1255–1262. doi:10.1001/jamaneurol.2017.2396
[4] Researchers Find CTE in 345 of 376 Former NFL Players Studied | Chobanian & Avedisian School of Medicine, https://www.bumc.bu.edu/camed/2023/02/06/researchers-find-cte-in-345-of-376-former-nfl-players-studied/ (last visited Dec 4, 2024).
[5] BU Researchers Find CTE in 99% of Former NFL Players Studied, Boston University</span> (2017), https://www.bu.edu/articles/2017/cte-former-nfl-players/ (last visited Dec 5, 2024).
[6] Lauren Ezell, Timeline: The NFL’s Concussion Crisis – League of Denial: The NFL’s Concussion Crisis, FRONTLINE, http://www.pbs.org/wgbh/pages/frontline/sports/league-of-denial/timeline-the-nfls-concussion-crisis/ (last visited Dec 5, 2024).
[7] Fox’s Aikman takes a pass on concussion issue, http://www.jsonline.com/blogs/sports/113137639.html (last visited Dec 5, 2024).
[8] See [6], Lauren Ezell, Timeline: The NFL’s Concussion Crisis – League of Denial: The NFL’s Concussion Crisis, FRONTLINE, http://www.pbs.org/wgbh/pages/frontline/sports/league-of-denial/timeline-the-nfls-concussion-crisis/ (last visited Dec 5, 2024).
[9] Jeanne Marie Laskas, The Brain That Sparked the NFL’s Concussion Crisis, The Atlantic (Dec. 2, 2015), https://www.theatlantic.com/health/archive/2015/12/the-nfl-players-brain-that-changed-the-history-of-the-concussion/417597/ (last visited Dec 5, 2024).
[10] Gary Mihoces Sports USA TODAY, Attorney: Report Backs Ex-Players’ Brain Damage Claims, USA TODAY, https://www.usatoday.com/story/sports/nfl/steelers/2012/11/16/nfl-concussions-mike-webster/1710567/ (last visited Dec 8, 2024).
[11] See [9], Jeanne Marie Laskas, The Brain That Sparked the NFL’s Concussion Crisis, The Atlantic (Dec. 2, 2015), https://www.theatlantic.com/health/archive/2015/12/the-nfl-players-brain-that-changed-the-history-of-the-concussion/417597/ (last visited Dec 5, 2024).
[12] Howard: Chris Henry findings sound alarm for football, ESPN.com (2010), https://www.espn.com/espn/commentary/news/story?page=hoiward/100629 (last visited Dec 8, 2024).
[13] Stringer v. National Football League, 474 F. Supp. 2d 894 | Casetext Search + Citator, https://casetext.com/case/stringer-v-national-football-league (last visited Dec 5, 2024).
[14] NFL, ex-Viking Stringer’s widow, settle lawsuit, ESPN.com (2009), https://www.espn.com/nfl/news/story?id=3861331 (last visited Dec 5, 2024).
[15] See [13], Stringer v. National Football League, 474 F. Supp. 2d 894 | Casetext Search + Citator, https://casetext.com/case/stringer-v-national-football-league (last visited Dec 5, 2024).
[16] See [13], Stringer v. National Football League, 474 F. Supp. 2d 894 | Casetext Search + Citator, https://casetext.com/case/stringer-v-national-football-league (last visited Dec 5, 2024).
[17] See [14], NFL, ex-Viking Stringer’s widow, settle lawsuit, ESPN.com (2009), https://www.espn.com/nfl/news/story?id=3861331 (last visited Dec 5, 2024).
[18] Dent v. National Football League, No. 19-16017 (9th Cir. 2020), Justia Law, https://law.justia.com/cases/federal/appellate-courts/ca9/19-16017/19-16017-2020-08-07.html (last visited Dec 8, 2024).
[19] Office of the Commissioner, Federal Food, Drug, and Cosmetic Act (FD&C Act), FDA (2018), https://www.fda.gov/regulatory-information/laws-enforced-fda/federal-food-drug-and-cosmetic-act-fdc-act (last visited Dec 8, 2024).
[20] Justice Manual | 9-132.000 - Labor Management Relations Act - 29 U.S.C. § 186 | United States Department of Justice, (2015), https://www.justice.gov/jm/jm-9-132000-labor-management-relations-act-29-usc-186 (last visited Dec 8, 2024).
[21] See [18], Dent v. National Football League, No. 19-16017 (9th Cir. 2020), Justia Law, https://law.justia.com/cases/federal/appellate-courts/ca9/19-16017/19-16017-2020-08-07.html (last visited Dec 8, 2024).
[22]The Eichholz Law Firm, NFL Concussion Lawsuit, The Eichholz Law Firm (Jul. 7, 2016), https://www.thejusticelawyer.com/nfl-concussion-lawsuit (last visited Dec 5, 2024).
[23] CLASS ACTION FIRST AMENDED COMPLAINT against NATIONAL FOOTBALL LEAGUE, INC for EASTERLING et al v. NATIONAL FOOTBALL LEAGUE, INC. :, Justia Dockets & Filings, https://docs.justia.com/cases/federal/district-courts/pennsylvania/paedce/2:2011cv05209/435351/4 (last visited Dec 8, 2024).
[24] Turner v. Nat’l Football League & NFL Props. (In re Nat’l Football League Players’ Concussion Injury Litig.), 2:12-md-02323-AB | Casetext Search + Citator, https://casetext.com/case/turner-v-natl-football-league-nfl-props-in-re-natl-football-league-players-concussion-injury-litig-5 (last visited Dec 4, 2024).
[25]Junior Seau’s family settles wrongful death lawsuit with NFL - CBS News, (2018), https://www.cbsnews.com/news/junior-seau-family-settle-with-nfl-over-2012-suicide-cte-2018-10-05/ (last visited Dec 8, 2024).
[26] NFL concussion lawsuit changes with Easterlings death | Steinberg Law Firm, (Apr. 27, 2012), https://www.steinberglawfirm.com/blog/nfl-concussion-lawsuit-changes-with-easterlings-death/ (last visited Dec 8, 2024).
[27] Former NFL players denied compensation for brain trauma, PBS News (2024), https://www.pbs.org/newshour/show/former-nfl-players-denied-compensation-for-brain-trauma (last visited Dec 8, 2024).
[28] See [27], Former NFL players denied compensation for brain trauma, PBS News (2024), https://www.pbs.org/newshour/show/former-nfl-players-denied-compensation-for-brain-trauma (last visited Dec 8, 2024).
[29] In re National Football League Players' Concussion Injury Litigation, No. 2:12-md-02323-AB, MDL No. 2323 (E.D. Pa. 2012).
[30] 1947 Taft-Hartley Substantive Provisions | National Labor Relations Board, https://www.nlrb.gov/about-nlrb/who-we-are/our-history/1947-taft-hartley-substantive-provisions (last visited Dec 8, 2024).
[31] See [29], In re National Football League Players' Concussion Injury Litigation, No. 2:12-md-02323-AB, MDL No. 2323 (E.D. Pa. 2012).
[32] The Associated Press, NFL Agrees to End Race-Based Brain Testing in $1B Settlement on Concussions, NPR, Oct. 20, 2021, https://www.npr.org/2021/10/20/1047793751/nfl-concussion-settlement-race-norming-cte (last visited Dec 8, 2024).
[33] How does the NFL’s concussion protocol work? Explaining the five-step process for return to play | Sporting News, (2024), https://www.sportingnews.com/us/nfl/news/nfl-concussion-protocol-process-return/neo5aga3ey4c4zzvshu6exwf (last visited Dec 8, 2024).
[34] Glenn Cohen, Holly Fernandez Lynch & Christopher R. Deubert, A Proposal to Address NFL Club Doctors’ Conflicts of Interest and to Promote Player Trust, 46 Hastings Cent Rep S2 (2016), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5215412/ (last visited Dec 8, 2024).
[35] What are Guardian Caps? How are they used in the NFL?, ESPN.com (2024), https://www.espn.com/nfl/story/_/id/40909583/what-guardian-caps-how-used-nfl (last visited Dec 8, 2024).
[36] Jaclyn Jacobi et al., The National Football League Concussion Protocol: A Review, 19 HSS Journal®: The Musculoskeletal Journal of Hospital for Special Surgery 269 (2023), https://journals.sagepub.com/doi/10.1177/15563316231177207 (last visited Dec 8, 2024).
[37] Don Brady, A Preliminary Investigation of Active and Retired NFL Players' Knowledge of Concussions (Ph.D. dissertation, The Union Institute and University, 2004).
[38] Sources: Doctor who evaluated Tagovailoa fired, ESPN.com (2022), https://www.espn.com/nfl/story/_/id/34702740/unaffiliated-neurotrauma-consultant-evaluated-miami-dolphins-qb-tua-tagovailoa-fired-several-mistakes-source-says (last visited Dec 8, 2024).
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