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Free agent who hurt knee at Seahawks tryout not eligible for workers comp

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Free agent who hurt knee at Seahawks tryout not eligible for workers comp

A National Football League free agent who injured his knee at a Seattle Seahawks minicamp tryout is not entitled to workers compensation benefits, the Washington Court of Appeals has ruled.

Courtney Robinson, who became a free agent in August 2009 when he was released from his NFL player contract with the Philadelphia Eagles, was invited to try out for the Seattle Seahawks in April 2010, court records show.

John Idzik, the team's former vice president of football administration, described the three-day, off-season, voluntary minicamp tryout Mr. Robinson was invited to as an opportunity to meet players, give them physical exams and watch their movements in person, according to records.

“The first thing we do with all of our tryouts coming to the Seahawks is … have them sign a waiver of liability so they understand they're not an employee of the Seahawks, that we're granting them a tryout, that during the tryout they're in essence waiving liability of the Seahawks if anything were to happen to them during the tryout,” Mr. Idzik testified, according to court records. “At that point, if they're willing to go on, which most all of them are, we conduct the interviews, and we conduct the physical examinations and … the tryout.”

Records show that Mr. Robinson signed a tryout waiver and release of liability on April 12, 2010, prior to passing the physical examination.

Mr. Robinson said he injured his knee the next day during an on-field drill, according to records. He said when he “was back peddling, my foot got caught in the ground, or whatnot, but as I dove for the ball I was injured, you know, on that current play.”

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He was told he tore his meniscus and booked a return flight home that evening, records show. Mr. Robinson filed an application for benefits with the Washington state Department of Labor & Industries in June 2010. The department denied the claim, at which point Mr. Robinson filed an appeal with the state's Board of Industrial Insurance Appeals.

According to records, the board denied Mr. Robinson's claim under the Industrial Insurance Act, as he wasn't an employee of the Seahawks when he was injured during the minicamp, noting that the Seahawks didn't pay him “any form of wage or other compensation.”

Mr. Robinson then filed an appeal of the board's final order, records show.

On May 27, a three-judge panel of the Washington Court of Appeals unanimously supported the board's findings that Mr. Robinson was not an employee of the Seahawks and, therefore, is not entitled to workers compensation benefits.

“The Seahawks expressly informed Robinson and his agent that attendance at the minicamp did not guarantee a place on the team or create an employment relationship,” the ruling reads.