Thursday, October 16, 2014

Concussion Update (Part Six)

Unlike my prior concussion updates, this time I do not have a detailed timeline of an improperly handled head injury.  This doesn’t mean that there were any improperly handled head injuries recently.   It just means that I did not happen to see them.

I did see a serious head injury in the Denmark-Portugal Euro qualifier game where Danish left back Nicolai Boilesen was hit in the side of a head with a misdirected clearance.  He was immediately removed from the game.  Since this is what should happen in such cases, I have nothing to complain about.
I have an update on the injury to Thibaut Courtois which I discussed in my last concussion update.  Courtois has gone on record defending the handling of his head injury. He stated that the Chelsea doctor did a good job.  She asked him the questions she needed to ask and he was able to respond appropriately.  He was feeling well so he did not need to come off.  He did not lose consciousness or have a headache at the time, but after a few minutes he felt worse and worse so he needed to come off.
The most interesting quote is his statement that “I had some neck pains, dizziness, and headaches for a few days afterwards.”  He then notes that according to the neurological tests his brain was responding correctly so he traveled to Belgium and played every minute of their game against Andorra on Friday 10 October 2014.
Something is very wrong here.  If we give everyone the benefit of the doubt and assume that by “a few days” Courtois meant only two days that means that he was still suffering concussion symptoms on 7 October 2014.   The process of returning to play after suffering a concussion is supposed to take a minimum of five days after symptoms cease.  (See here and here.)
The protocol involves a specific sequence of steps.  You only progress to the next step if you remain symptom free in the prior step.  First, you have one symptom free day resting completely.  The next day you may engage in light aerobic exercise.  The third day you may engage in moderate exercise.  The fourth day you may engage in non-contact exercise.  The Fifth day you can engage in normal practice.  Only if you have remained symptom free through this process can you safely return to play on the sixth day.
Assuming that Courtois was symptom free on Wednesday, that should have been the first of the six days.  Assuming he suffered no further symptoms, the earliest he should have returned to play was Monday 13 October 2014.  In other words, the Belgium national team flagrantly disregarded the best medical practices for how concussions should be handled and, instead, chose to risk Courtois’ career and life by rushing him back to play against Andorra.   It is difficult to view this as anything but grossly irresponsible and stupid behavior on the part of the Belgium national team.  If I were Chelsea FC, I would not be too happy about this treatment of my concussed player although, perhaps, by not removing him from the game immediately, Chelsea might understandably recognize that they had forfeited the moral high ground.
In any case, nothing about the way this was handled suggests to me that the new focus on better treatment for concussed football players is anything other than a publicity stunt. (To be fair, Belgium may not be participating in the publicity stunt.) Certainly, it is difficult to look at the Courtois incident and see where anyone, including Courtois himself, put his long-term health ahead of the trivial short term interests of his club and national team.
This cavalier disregard for concussed players is the primary reason behind the lawsuit filed against FIFA in California.  I have reviewed the 138 page Class Action Complaint against FIFA and various American soccer entities (I will call it soccer when referring to American organizations) concerning concussions.  Of necessity, substantial parts of the document are devoted to standard legal things such as proving that the United States Northern District for the Northern District of California has jurisdiction over FIFA and repeating the same thing over and over again because that is what lawyer do.  Nevertheless, the document as a whole is an in depth primer on the current status of the science of concussions in sports.
The complaint includes detailed information about the various studies that have established the types of dangers concussions represent both to younger players and elite athletes as well as to men and women.  (Generally speaking, women, and particularly girls, are more susceptible to concussions than men and boys and younger people are more at risk than adults.) The document contains a great deal of information as to what actions should be taken to mitigate the risk of concussions both before and after they occur.
Of particular interest is the relief sought by the plaintiffs and the legal basis for their claims.  The lawsuit claims that FIFA and other entities were negligent by violating their duty to protect all soccer players by failing to take appropriate action in light of the knowledge they had or should have had about concussions and the consequences they cause in both the short and long term.  In particular, the plaintiffs claim that FIFA and the other entities were negligent by
a. Failing to educate players and their parents concerning symptoms that may indicate a concussion has occurred;
b. Failing to warn of the risk of unreasonable harm resulting from repeated concussions, the accumulation of subconcussive hits, and heading;
c. Failing to disclose the risks of long-term complications from repeated concussions and return to play;
d. Failing to disclose the role of repeated concussions or accumulation of subconcussive hits in causing chronic life-long cognitive decline;
e. Failing to promulgate rules and regulations to adequately address the dangers of repeated concussions and accumulation of subconcussive hits, and a return to play policy to minimize long-term chronic cognitive problems;
f. Concealing and misrepresenting pertinent facts that players and parents needed to be aware of to make determinations of the safety of return to play;
g. Failing to adopt rules and reasonably enforce those rules to minimize the risk of players suffering debilitating concussions;
and
i. Other acts of negligence or carelessness that may materialize during the pendency of this action.
The complaint asked for injunctive relief requiring FIFA and the other entities to adopt rules to deal with these problems.  The lawsuit focuses on the laws of the game promulgated by FIFA which all football and soccer entities worldwide are compelled to follow at the risk of being evicted from FIFAdom.  FIFA’s insistence that everyone must play football their way or not at all is probably what makes them susceptible to this type of lawsuit at least in the United States.
If, for example, an official football or soccer league wanted to create a system whereby players could be removed by the game temporarily and replaced while they were being evaluated to see if they suffered a concussion, that rule would be in direct violation of the laws of the game.
Modifications
Subject to the agreement of the member association concerned and provided the principles of these Laws are maintained, the Laws may be modified in their application for matches for players of under 16 years of age, for women footballers, for veteran footballers (over 35 years of age) and for players with disabilities.
Any or all of the following modifications are permissible:
• size of the field of play
• size, weight and material of the ball
• width between the goalposts and height of the crossbar from the ground
• duration of the periods of play
• substitutions
Further modifications are only allowed with the consent of the International Football Association Board.
While the reference to substitutions, might suggest that football leagues could create rules allowing temporary substitutes to evaluate head injuries, the Laws of the Game dealing with substitutions make it quite clear that a substituted player may not return to the game:
To replace a player with a substitute, the following conditions must be observed:
• the referee must be informed before any proposed substitution is made
• the substitute only enters the field of play after the player being replaced has left and after receiving a signal from the referee
• the substitute only enters the field of play at the halfway line and during a stoppage in the match
• the substitution is completed when a substitute enters the field of play
• from that moment, the substitute becomes a player and the player he has replaced becomes a substituted player
• the substituted player takes no further part in the match
• all substitutes are subject to the authority and jurisdiction of the referee, whether called upon to play or not
Under these rules, it is possible that FIFA would be okay with removing and temporarily replacing players in under 16 leagues—assuming that such actions maintain the principles of the Laws.  However, professional leagues quite simply cannot make such changes because they are prohibited.  FIFA would no doubt object to changing such a significant rule without their permission.  This power which FIFA has deliberately gathered to itself is the opening that allows FIFA to be the target of this and other similar lawsuits.  Moreover, because FIFA does business in every country in the world, courts throughout the world would have jurisdiction over FIFA.
The lawsuit asks that FIFA be required to adopt a medical monitoring process to watch over persons who have played football who may in the future manifest the physical and long term mental effects of their head injuries.  In a way, this is not unlike the remedy that has been sought (and granted) in the NFL concussion lawsuit.  Specifically, the complaint asks that FIFA be required to:
a. Establishing a trust fund, in an amount to be determined, to pay for the medical monitoring of all past, current, and future FIFA athletes, as frequently and appropriately as necessary;
b. Notifying all Medical Monitoring Class members in writing that they may require frequent medical monitoring; and
c. Providing information to treating team physicians to aid them in detecting concussion or sub-concussions and to assist them in determining when the student-athlete is subjected to an increased risk of harm.
The difference is that the NFL lawsuit obtained (grossly inadequate) monetary damages while the FIFA law suit appears to be asking only for monitoring and testing of athletes who may have suffered injuries, but not compensation for their injuries either in the form of money for pain and suffering, lost income, or medical expenses.  However, the request for relief at the end of the Complaint also asks for “[a]n award to the Plaintiffs and Class for such other and further relief as the Court deems just and proper.”  While this is standard legal boilerplate, it does leave the door open for a monetary award which could be quite sizable.
 
The most significant barrier to the success of this lawsuit is likely to be the certification of the Plaintiffs as a class.  Recent developments in American Jurisprudence and the current pro-business slant of the United States Supreme Court have made it more difficult to pursue class actions.  I am not an expert in this field of law so I cannot evaluate whether the lawyers in this case have done enough to establish that a class action is appropriate.  I have no doubt that if the proposed class were being evaluated 20 or 30 years ago it would pass muster.  I also have no doubt that the lawyers who prepared this lawsuit are competent and do not intend to waste their time.  They must believe they had established a viable class.  No doubt they are hoping both to fix a serious problem and be well compensated for their efforts
The class in this case purports to cover basically everyone who has played organized soccer in the United States from 2002 to the present.  The 2002 date is apparently chosen because the first international symposium on concussions was held in Vienna, Austria in 2001.  The theory of the case is that following that conference FIFA and everyone else should have recognized the serious problems of concussions and taken immediate action.  To support this claim, the complaint discusses in some detail the findings and recommendations included in the protocol that emerged from that conference.
This lawsuit is a serious threat to FIFA’s way of doing business.  The orders that could result from a successful prosecution of this lawsuit might change the way that football is played worldwide.  On the other hand, it might not.
FIFA may be able to convince the court that the class action lawsuit is not appropriate and, obviously, this is not the sort of case that can be litigated by individual plaintiffs.  They also may be able to convince the court that it should not assert jurisdiction over FIFA and that only the American soccer entities should be held responsible for the rules in America.  As a lawyer, my best understanding of the law is that both of these claims would be weak but I am cynical enough to recognize that powerful entities get more favorable treatment in courts and I also recognize that I am not an expert in this area of the law.
Even if FIFA does, ultimately, lose this lawsuit, it is possible that any orders that result of the lawsuit would only apply to the United States.  FIFA might be able to choose to leave the concussion rules and other issues unchanged in the rest of the world but simply change things in the United States.  I would think that this would leave FIFA wide open to further lawsuits in other countries, but who knows.
FIFA might be able to convince the court that their actions with respect to concussions were reasonable either because concussions are not as harmful as the plaintiffs claim or because they could not have known how harmful they would be at the early date that the lawsuit alleges.  The problem for this sort of response is that the NFL case set something of a precedent that supports the idea that FIFA should have known about the dangers of concussions and taken early action.  On the other hand, the NFL case had some smoking guns indicating that the NFL was covering up evidence of the effects of brain injuries on its players.  As far as I know, no similar evidence of a FIFA cover-up exists.  Of course, if there is an ongoing cover-up, I would not know about it.
Finally, the plaintiffs might settle the lawsuit.  Most lawsuits are settled.  The could result in some lesser remedy, perhaps some money for the members of the class, and hefty attorney fees for the plaintiffs’ law firm.  There is no way to predict what might result from a settlement.
FIFA has not yet responded to the complaint.  According to a paralegal at the plaintiffs’ law firm, their response is not due until sometime in November.  The American entities are supposed to respond earlier than that.  I will review the responses when they are filed and if there is anything worth reporting, I will do yet another concussion update.

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