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Bush v. St. Louis Rams

United States District Court for the Eastern District of Missouri
2016 WL 3125869 (2016)


Facts

Reggie Bush (plaintiff) was a running back in the National Football League (NFL). Bush was playing in a game against the St. Louis Rams (defendant) in the Rams’ stadium. During the game, Bush attempted to slow down after running out of bounds. Bush then slipped on a concrete surface that surrounded the turf playing field. Bush suffered a season-ending knee injury due to the slip. Bush brought suit against the Rams, claiming the abrupt change in surface was not reasonably safe. Bush stated that the team created an unreasonable risk of injury due to their negligent maintenance of this dangerous condition. Bush’s claim was based on state tort law and he brought suit in state court. The Rams responded by removing the suit to the federal courts on the grounds that the NFL’s collective-bargaining agreement governed the terms of Bush’s employment. As such, the Rams claimed, Bush’s state law claim was preempted under federal labor law. Bush moved to remand the case to state court.

Rule of Law

Issue

Holding and Reasoning (Hamilton, J.)

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