Court: Former Washington Commanders player can get workers’ comp for training camp injury

A former Washington Commanders football player who ruptured his Achilles tendon during training camp in 2023 is entitled to workers’ compensation benefits for the injury, the Appellate Court of Maryland ruled this week.

The Wednesday ruling upheld an earlier Prince George’s County Circuit Court decision that said Curtis Brooks, who signed with the team Aug. 3, 2023, to play on the defensive line, was a “covered employee” when his injury happened three days later during an early training camp practice.

According to the 20-page ruling, Brooks never made it on the Commanders’ active roster and didn’t play a game.

But the terms of his contract at the time said it “covers 1 football season(s), and will begin on the date of execution, and end on the last day of the 2023 League Year, unless extended, terminated, or renewed as specified elsewhere in this contract.”

In terms of injury, another part of the contract states, “Unless this contract specifically provides otherwise, if Player is injured in the performance of his services under this contract and promptly reports such injury to the Club physician or trainer, then Player will receive such medical and hospital care during the term of this contract.”

Brooks, who hasn’t played in the National Football League since his injury, filed a worker’s compensation claim with the Maryland Workers’ Compensation Commission in March 2024. Two months later, the commission rejected his claim, saying Brooks did not qualify as a covered employee in the state and that the injury occurred at a practice at the team’s training facility in Ashburn, Virginia.

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Brooks appealed to the county circuit court, which held a hearing on May 6, 2025.

The circuit court reversed the commission decision, writing that all players’ primary employment and home games with the Commanders in the National Football League are at Northwest Stadium in Prince George’s County.

A three-judge panel with the Appellate Court – Judge Stuart R. Berger who wrote the opinion, and Judge Rosalyn Tang and Senior Judge James A. Kenney III – affirmed the county Circuit Court’s decision.

In an email Friday, a team official said the Commanders would not be commenting on the case. Representatives with the workers’ comp commission did not respond to requests for comment.

According to the court document, Rob Rogers, the Commanders senior vice president of football operations, testified in circuit court that Brooks likely would have played in two preseason games in Maryland, but he “likened the games to a tryout.”

But when asked directly by Brooks’ attorney, “At no time before Mr. Brooks signed his contract, did you tell him that you did not think he was going to make the team, did you?” Rogers replied, “No.”

The circuit court entered an verbal ruling for Brooks on May 13, 2025.

In part, the court said, “This is just a contract for a season. And at the time, on August 6 of 2023, he [Brooks] was an employee of this football team. And quite honestly, there was an argument about, well, you know, ‘consistent and predictable.’ But what this contract says is that he is employed by the Commanders for the 2023 NFL season.”

On appeal to the Appellate Court of Maryland, the Commanders focused on the fact that Brooks was injured in Virginia, and that his employment with the team “was not consistent and predictable” because he had only been with the team for three days prior to his injury “and was not likely to play games in Maryland on a consistent and predictable basis.”

But Berger wrote that the team “invites us to engage in speculation regarding how many games Mr. Brooks would have played in Maryland to determine whether Mr. Brooks would have been covered. We decline to engage in such speculation. Indeed, effectively establishing a certain number of games that would meet the threshold for ‘regular’ and ‘predictable’ employment is an inexact estimation.”

Brooks finished his collegiate career in 2021 at the University of Cincinnati as a defensive tackle and an All-American Athletic Conference First Team honoree. He was drafted in the sixth round in 2022 by the Indianapolis Colts.

He was transferred to the Colts’ practice squad and then released in December 2022 before signing with the Tennessee Titans practice squad in January 2023. But he was cut by the Titans in July, during preseason camp, and signed by the Commanders in August of that year.