The Death of Tyler Skaggs and Potential Liability of the Los Angeles Angels

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On July 1, 2019, Los Angeles Angels starting pitcher, Tyler Skaggs, was found dead in a hotel room in Texas several hours before his team was scheduled to play the Texas Rangers. The police in Southlake, Texas, said they found Skaggs, 27, dead in a room at the team hotel after responding to a call about an unconscious male.

After an autopsy was performed, it was discovered that Skaggs died by choking on vomit after using drugs and alcohol, according to the Tarrant County, Texas medical examiner’s office. High levels of opioids, including fentanyl, oxycodone, and oxymorphone were found in his system, as well as alcohol, according to toxicology results. According to the autopsy report, the death was an accident.

Soon after the results of the autopsy came out, Skaggs’ family released a statement: “[w]e are grateful for the work of the detectives in the Southlake Police Department and their ongoing investigation into the circumstances surrounding Tyler’s death. We were shocked to learn that it may involve an employee of the Los Angeles Angels. We will not rest until we learn the truth about how Tyler came into possession of these narcotics, including who supplied them.”

This statement by the Skaggs family prompted many to speculate if a legal battle between the family and the Angels will follow. As of now, no official lawsuit has been filed as the investigation surrounding the death of Skaggs continues. However, both sides have retained attorneys in Texas, where Skaggs’ death occurred.

The biggest question is how it came about that those drugs were ingested. Skaggs’ method for obtaining the drugs is also of critical importance. Under federal law, the opioids found in his system — fentanyl and oxycodone — are illegal to possess without a medical prescription. Both drugs are also prohibited directly or indirectly by MLB and MLBPA’s drug policy.

In Texas, before an employer can be held liable for its employees’ negligence, the following two questions must be answered:

  1. At the time of the negligent act, was the worker an employee (as opposed to an independent contractor) of the employer?
  2. At the time of the negligent act, was the worker acting in the course and scope of his or her employment?

The Angels could potentially be liable if an employee, such as a team doctor, provided the drugs to Skaggs. Even if the Angels were not aware of the situation, the team could still potentially be held liable if the employee was acting within the scope of his employment. In addition to the Angels, other medical providers and pharmacies could also be liable for Skaggs’ death.

Texas law allows the surviving children, spouse, or parents of a decedent to pursue compensation for losses they have personally sustained as a result of the loss of their loved one. The damages available in a wrongful death action in Texas include the following:

  • The lost earning capacity of the decedent
  • The loss of an inheritance, including what the decedent would have reasonably been expected to earn and gift had he or she lived
  • The loss of companionship, society, comfort, and love
  • The emotional pain and mental anguish suffered by survivors
  • Lost value of household services

Skaggs was married for only eight months prior to his death. He had been a regular in the Angels’ starting pitching rotation since late 2016, when he returned from Tommy John surgery. He was selected in the first round of the 2009 MLB draft and made his MLB debut in 2012 with the Arizona Diamondbacks. He struggled with injuries repeatedly over the past three seasons, however, he was in the midst of one of the best seasons of his career. Skaggs was going to be a free agent after the 2020 MLB season and was in line for a potential lucrative contract. Based on recent contracts signed by starting pitchers in MLB, Skaggs could potentially have signed a multiyear contract worth over $50 million. 

It remains to be seen whether Skaggs’ family will actually file a lawsuit against the Angels. However, if a lawsuit is filed, it could potentially be worth tens of millions of dollars.

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