Aaron Patrick v. National Football League

I.

FACTUAL AND PROCEDURAL BACKGROUND

Patrick is a professional athlete who plays for the Denver Broncos, a member team of the NFL. FAC ¶ 1. He is a member of the NFL Players Association (“NFLPA”) and thus the conditions of his employment are set by a collective bargaining agreement (“CBA”) between the NFLPA and the NFL. See generally Ntc. of Removal, Ex. 21 (CBA) [Doc. # 1-22]. The NFL Management Council, which is the bargaining representative of the NFL and its 32 member clubs (including Defendant Los Angeles Chargers), is a signatory to the relevant CBA. Id. at 18, 23, 351; see also MTD at 7.

On October 17, 2022, Patrick was injured during a football game between the Denver Broncos and the Los Angeles Chargers which occurred at SoFi stadium, the host of the Chargers’ home games. FAC ¶ 17. The injury occurred immediately after Patrick attempted to tackle the Chargers’ punt returner, DeAndre Carter, near the 21-yard-line. Id. During that play, Patrick’s momentum carried him off the field and onto the sidelines where, attempting to avoid contact with the NFL’s TV Liaison, Moe “Greenhat,” his cleats became lodged in the cords and cables connected to the NFL’s instant replay…