On August 29, 2013, the Commonwealth Court of Pennsylvania ruled against former Pittsburgh Steelers player Ainsley T. Battles in a claim for workers’ compensation benefits based on a ruling that Battles’ injury did not result in a compensable loss of earnings.
The Steelers signed Battles to a one-year contract in 2004-2005, however, his season unfortunately ended during Week One when claimant tore his left hamstring. The team physician, Dr. James Bradley, performed surgery three days after the injury and Battles underwent a lengthy period of rehabilitation from 2004 into the summer of 2005. The Steelers did not re-sign Battles, but permitted him to continue his rehabilitation and provided a $50,000 severance payment. Ultimately, claimant was medically cleared to play in the NFL on August 20, 2005, but was unable to secure a position with the Steelers or any other team and retired from football altogether in 2006.
In 2007, Battles filed a claim for total disability benefits from September 2004 to January 2007 and partial disability benefits thereafter based on his argument that the hamstring injury adversely affected his ability to play professional football in terms of reduced physical abilities, as indicated by, among other things, a reduced 40-yard dash time, an inability to find work with the Arena Football League, and a medical opinion from his physician that “at extremes,” Battles’ leg would not perform as well as it would have pre-injury.
In opposition, the Steelers denied the claim and presented the testimony of Dr. Bradley, who opined that he surgically repaired Battles’ leg, that the rehabilitation progressed normally, and that he had cleared Battles to physically play in the NFL without restrictions. Additionally, Dr. Jeffrey Kann testified that on an August 25, 2008 examination, claimant had “superb results” from his surgery, was fit to play in the NFL, and had only complaints that his surgically-repaired leg fatigued more easily than his right. Finally, the testimony of Kevin Colbert, the Steelers Director of Football Operations, testified that Battles’ contract was not renewed because the Steelers had three other safeties (including Troy Polamalu, Chris Hoke, and Mike Logan) had found a “better player” in Tyrone Carter, and that they did not look solely to claimant’s speed in the 40-yard dash in determining whether a spot on the team would be granted. Colbert also testified that the Steelers had paid for all necessary medical treatment and paid Battles his contractually owed $205,000 for the 2004-2005 season.
Ultimately, the Workers Compensation Judge determined that Battles lost his spot because the Steelers had found a better football player and that claimant’s work injury did not result in a compensable loss of time. The Court ultimately affirmed, finding that claimant initially had no loss of earnings when he was paid during the 2004-2005 during his lost season that the testimony of Drs. Bradley and Kann were credible in that the injury did not prevent Battles from playing in the NFL. Additionally, it credited the testimony of Colbert that the reduced 40-yard dash time was not relevant to the team’s decision to go with another player. As a result, it affirmed the findings that claimant was “not entitled to disability benefits because he failed to prove that his work injury caused him to experience a loss of earnings.”
For more, see Ainsley T. Battles v. Workers’ Compensation Appeal Board (Pittsburgh Steelers Sports Inc., No. 225 C.D. 2013, 2013 Pa. Commw. Unpub. LEXIS 677 (August 29, 2013).