Curtis Brooks never played a single down for the Washington Commanders, but Maryland's second-highest court has ruled he still deserves workers' compensation for the torn Achilles tendon he suffered three days into training camp. The Appellate Court of Maryland determined this week that Brooks was a covered employee under state law at the moment he got hurt, even though the injury happened in Virginia and he never set foot on a Maryland football field.
Brooks signed with the Commanders on August 3, 2023, to play defensive line, and he ruptured his Achilles tendon on August 6, 2023, at the team's training facility in Ashburn, Virginia, according to WTOP News. He was never on the Commanders' active roster and has not played in the NFL since. The team's home field, Northwest Stadium, sits in Prince George's County, Maryland, and that geography turned out to matter a great deal to the court.
A Claim Rejected, Then Revived
Brooks filed his workers' compensation claim in March 2024, but the Maryland Workers' Compensation Commission rejected it two months later, finding that the injury occurred at the team's Ashburn training facility and that Brooks did not qualify as a covered employee in Maryland, per the same WTOP account. Brooks appealed, and the Prince George's County Circuit Court held a hearing on his case in May 2025 before reversing the commission's decision, ruling that Brooks was in fact a covered employee because Commanders players' primary employment and home games are at Northwest Stadium.
The circuit court entered its verbal ruling in Brooks's favor on May 13, 2025. The Commanders then took the fight to the Appellate Court of Maryland, arguing that Brooks's injury in Virginia did not qualify for Maryland workers' compensation and that his brief tenure with the team was not consistent and predictable enough to establish regular employment in the state, a position the court would ultimately reject.
The Court's Reasoning
Writing for the panel in the case docketed as *In the Matter of Curtis Brooks* (No. 549, Sept. Term 2025), Judge Stuart R. Berger affirmed the circuit court's decision and declined to speculate about how many Maryland games Brooks would have played had he stayed healthy, according to News From The States. The panel, which also included Judge Rosalyn Tang and Senior Judge James A. Kenney III, held that courts will not engage in post-hoc guesswork about a player's odds of making the roster when deciding coverage. What matters, the court found, is that a valid seasonal contract existed at the moment of injury.
That reasoning leaned on Section 9-203(a)(2) of Maryland's Labor and Employment Code, which makes a worker a covered employee even while performing duties outside the state on a casual, incidental, or occasional basis, so long as the employer regularly employs people within Maryland. The same report notes that Brooks's contract began on the date of execution and covered one football season, running through the last day of the 2023 league year unless extended, terminated, or renewed. His agreement also provided medical and hospital care for injuries sustained while performing contract services.
What the Commanders Argued
During the proceedings, team vice president of football operations Rob Rogers testified that Brooks was an unproven player unlikely to make the final regular-season roster, and he likened the preseason games to a tryout, per the same WTOP account. Rogers also testified that Brooks likely would have played in two preseason games in Maryland had his Achilles held up. Under cross-examination, though, Rogers conceded that he never told Brooks before signing him that he was not expected to make the team, according to News From The States.
The Commanders, which operate legally as Pro-Football, LLC and are headquartered at Northwest Stadium in Landover while running daily practices and training camps in Ashburn, Virginia, will not comment on the case, per WTOP. That tri-state operational split — a Maryland stadium paired with a Virginia practice facility — has repeatedly put the franchise in the middle of jurisdictional disputes over where its players are legally considered to be working.
Built on Earlier Precedent
This is not the first time Maryland courts have sided with a Washington player hurt in Virginia. In the 2012 case *Pro-Football, Inc. v. McCants*, Maryland's Court of Appeals ruled that players injured during practices at the Ashburn facility qualify for Maryland workers' compensation because their primary employment duty is playing home games at Landover's stadium, according to FindLaw. A year earlier, in *Pro-Football, Inc. v. Tupa*, appellate judges found that punter Tom Tupa was eligible for Maryland benefits after a career-ending back injury during a 2005 preseason warmup, affirming that practice activities in Virginia are incidental to the team's regular season games in Maryland.
What sets the Brooks ruling apart, according to legal analysis from TTH Law, is that McCants and Tupa both involved players who had already performed work inside Maryland before their injuries. Brooks never did. By ruling that a seasonal contract creates an expectation of regular employment regardless of whether a player ever plays a game in the state or survives final roster cuts, the appellate court has set a standard that extends protection to fringe roster players and camp signees who may never appear in a regular-season box score.
Coverage Under Maryland's No-Fault System
Under Maryland's no-fault workers' compensation framework, covered employees receive mandatory medical care and partial wage replacement for job-related injuries, a system that shields employers from civil lawsuits while guaranteeing baseline protections for workers, as Hoodline has previously reported. Maryland law also prohibits private employment contracts from waiving those statutory rights, which is part of why the Commanders could not simply write around the issue in Brooks's contract.
Brooks's path to the Commanders was a winding one. He finished his collegiate career at the University of Cincinnati in 2021 as a First Team All-American Athletic Conference honoree at defensive tackle, then was drafted in the sixth round, 216th overall, by the Indianapolis Colts in 2022. The Colts released him that December, and he later joined the Colts' practice squad before signing with the Tennessee Titans' practice squad in January 2023. The Titans cut him that July, and he landed with Washington the following month — only to suffer the injury that would eventually reshape Maryland's workers' compensation law for professional athletes.
