A former Washington Commanders defensive lineman who was injured three days after signing with the team qualifies for Maryland workers’ compensation even though his injury occurred in Virginia and he never played a down for the franchise, the Appellate Court of Maryland has ruled.
Curtis Brooks signed with the Commanders on Aug. 3, 2023, and ruptured his Achilles tendon Aug. 6 while training at the team’s facility in Ashburn, Virginia. Brooks never made the active roster and has not played in the NFL since the injury. The Commanders play their home games at Northwest Stadium in Prince George’s County, Maryland.
Brooks filed a workers’ compensation claim in March 2024. The Maryland Workers’ Compensation Commission rejected the claim two months later, finding that Brooks was injured at the Virginia training facility and was not a covered Maryland employee. The Prince George’s County Circuit Court reversed that decision in May 2025.
The Commanders appealed, arguing that Brooks’ brief tenure did not establish sufficiently regular and predictable employment in Maryland. The Appellate Court of Maryland affirmed the circuit court’s decision in In the Matter of Curtis Brooks, No. 549, September Term 2025.
Judge Stuart R. Berger, writing for the panel, declined to base workers’ compensation coverage on speculation about whether Brooks would have survived roster cuts or eventually played a game in Maryland. The court instead focused on the employment relationship that existed when Brooks was injured. His seasonal contract began when it was executed and covered the 2023 football season unless it was extended, terminated or renewed.
The decision relied on Section 9-203(a)(2) of Maryland’s Labor and Employment Code. Under that provision, an employee can remain covered while performing duties outside Maryland on a casual, incidental or occasional basis when the employer regularly employs workers within the state.
Commanders vice president of football operations Rob Rogers testified that Brooks was an unproven player who was unlikely to make the regular-season roster and characterized preseason games as a tryout. Rogers also testified that Brooks likely would have played in two Maryland preseason games if he had remained healthy. Under cross-examination, Rogers acknowledged that Brooks had not been told before signing that the team did not expect him to make the roster.
The ruling follows earlier Maryland cases involving Washington players injured while working in Virginia. In Pro-Football, Inc. v. McCants, Maryland’s highest court held that players injured during practices at the Ashburn facility could qualify for Maryland workers’ compensation because playing home games in Maryland was a primary employment duty. In Pro-Football, Inc. v. Tupa, courts upheld Maryland benefits for punter Tom Tupa following a career-ending injury suffered during a preseason warmup in Virginia.
Brooks presented a different factual question because he had not yet performed work in Maryland before his injury. The appellate court nevertheless found his existing seasonal employment contract sufficient and refused to make coverage depend on a prediction about his chances of making the final roster.
For workers’ compensation adjusters, the decision shows why the location of an accident may not settle a jurisdictional question. Claims involving multistate employment can require examination of the employment contract, the employer’s regular operations, where the employee was expected to work and the state’s extraterritorial coverage statute. The Brooks decision also indicates that, under Maryland law, a claimant’s short tenure and uncertain prospects for continued employment do not necessarily defeat coverage when a valid employment relationship existed on the date of injury.
