NCAA Escapes Wrongful-Death Suit

In February 2016, at Mount Ida College in Massachusetts, after a two-hour off season workout with his football team, Michael Mazza returned to his dorm room and tragically died. According to an eyewitness, “[h]e sat on the couch and stiffened up. His head went back. His friends thought he was fooling around, but his lips were turning white and he wasn’t breathing.” Thirty minutes later, at 20 years old, Michael Mazza was pronounced dead. An autopsy revealed that the cause of death was “probable cardiac dysrhythmia,” or an abnormal heartbeat. According to Mazza’s mother, “[w]e were told that it was the equivalent of your house getting struck by lightning and never getting the power back on.”

At the time, Mazza’s death was just one of many tragic “sudden cardiac deaths” common among college and high school athletes, according to a 2016 study. In April 2018, Mazza’s parents filed a wrongful death lawsuit against both Mount Ida College and the NCAA, seeking compensatory damages for negligence and infliction of emotional distress.

The NCAA moved to dismiss the complaint on the ground that the risk facing Mazza “appears to have been wholly unforeseeable.” According to the NCAA, “[i]t would not be fair or proper to impose [the] alleged duty on the NCAA for an intrinsic, inevitable and infrequent risk of athletics that the NCAA does not cause or increase.” On March 1, 2019, Judge Linda Grasso Jones agreed and dismissed the Mazza’s claims against the NCAA and Mount Ida College for “failure to state a claim upon which relief may be granted.”

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