ANNAPOLIS, Md. — A Maryland appeals court has ruled that former Washington Commanders defensive tackle Curtis Brooks can be considered a covered employee under Maryland workers’ compensation law even though he was injured during practice in Virginia and never played a game for the team in Maryland.
In an opinion filed Aug. 26, 2026, the Appellate Court of Maryland affirmed a Prince George’s County Circuit Court ruling that Brooks was a covered employee when he ruptured his left Achilles tendon during Commanders training camp in August 2023.
The ruling does not itself award Brooks workers’ compensation benefits. Instead, it resolves the threshold question of whether Maryland’s workers’ compensation system can cover him and sends the matter back for further proceedings.
Brooks signed a standard NFL Player Contract with the Commanders on Aug. 3, 2023, at the team’s training facility in Ashburn, Virginia. Three days later, on Aug. 6, he ruptured his left Achilles tendon during practice.
At the time, Brooks had never appeared in a game for Washington and had not performed any of his football duties in Maryland.
He filed a workers’ compensation claim with the Maryland Workers’ Compensation Commission on March 7, 2024. The commission denied the claim that May, finding Brooks was not a covered employee under Maryland law. Brooks appealed to the Circuit Court for Prince George’s County, which reversed the commission’s decision.
The Commanders then appealed.
Court Rejects Argument That Brooks Was Merely Trying Out
The dispute centered on where Brooks should legally be considered employed.
The Commanders practice and hold training camp in Ashburn, Virginia, while their home games are played at Northwest Stadium, formerly FedEx Field, in Landover, Maryland. During the preseason and regular season, the team plays an equal number of home and away games.
The team argued Brooks was not regularly employed in Maryland because he had been with the Commanders for only three days, had never played a game for the team and was unlikely to make either the active roster or practice squad.
Rob Rogers, the Commanders’ senior vice president of football operations, testified that seven other players were competing for a limited number of defensive tackle positions and that it was “unlikely” Brooks would make the roster or practice squad.
Rogers acknowledged, however, that Brooks likely would have appeared in preseason games, including two home games scheduled in Maryland.
The appellate court rejected the argument that Brooks’ brief tenure amounted only to a tryout.
Judge Stuart R. Berger, writing for the court, noted that Brooks had signed an NFL contract expressly stating that the Commanders employed him as a “skilled football player.” The contract covered the 2023 league year and required Brooks to participate in training camp, practices and all preseason, regular-season and postseason games scheduled by the club.
The court concluded that Brooks and the Commanders were already in an ongoing employment relationship when he was injured.
Previous Commanders Cases Played Major Role
The court relied heavily on two earlier Maryland cases involving former Washington players, Pro-Football, Inc. v. Tupa and Pro-Football, Inc. v. McCants.
Those cases established that determining where a professional football player is regularly employed involves more than simply counting how many hours the player spends in each state.
In the earlier rulings, Maryland courts found that the principal purpose of a professional football player’s job is to play games, while practices and training are undertaken in preparation for those games.
The appellate court applied that reasoning to Brooks even though his injury occurred before he had the opportunity to play for Washington in Maryland.
The court found that Brooks’ contract contemplated his participation in Commanders games and that, had his employment continued, more of those games would have been played in Maryland than in any other individual state.
The court also declined the Commanders’ request to speculate about whether Brooks ultimately would have survived roster cuts or how many games he might have played.
“At the time of his injury, Mr. Brooks was employed by the Team,” the court wrote, emphasizing that his contract required him to participate fully in the club’s games and practices.
Under Maryland law, an employee working outside the state may still qualify as a covered employee when that out-of-state work is casual, incidental or occasional and the employer regularly employs the person in Maryland.
The appellate court determined that, in the context of professional football, Brooks’ Virginia practice work was incidental to the central purpose of his employment — playing football games for the Commanders.
Decision Sends Case Back For Further Proceedings
The court ultimately affirmed the Prince George’s County Circuit Court judgment, finding no error in its determination that Brooks was a covered employee under Maryland law.
The case will return to the Maryland Workers’ Compensation Commission for further proceedings consistent with that ruling.
The decision could have implications beyond Brooks’ individual claim because the Appellate Court of Maryland designated the opinion for publication, making its reasoning available as precedent in future Maryland cases involving similar employment and workers’ compensation questions.
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