When you hear about athletes dying of heat-related causes, the first thought in most peoples’ minds is late-summer preseason football practices. The athletes, usually overweight and out of shape, are forced to participate in conditioning drills during the hottest days of the year — often while wearing equipment and helmets, and in some cases on synthetic turf, increasing the temperature on the field.
According to data from the University of North Carolina’s National Center for Catastrophic Sport Injury Research, 12 football players died from heatstroke during football activities between 2017 to 2021, the most recent year for which data is available. In the 25-year period spanning 1996-2021, 68 football players died from heat-related causes.
Fortunately, football coaches at all levels are much more aware of the dangers of dehydration and heat stroke, as well as the need for regular water and shade breaks and smarter scheduling around the hottest hours of the day. Unfortunately, it took the NCCSIR’s mounting statistics and the high-profile deaths of Korey Stringer of the Minnesota Vikings in 2001 and Jordan McNair of the University of Maryland in 2018 to raise such awareness.
While football might get the lion’s share of media attention, coaches in every sport need to be aware of the danger to athletes posed by extreme heat and intense conditioning drills. The NCCSIR reports that in 2020-21 alone, six high school and college athletes suffered heat stroke. One case that illustrates the importance of schools having established safety guidelines as to when practices can be held, and when athletes should get rest breaks for water and shade during warm-weather practice sessions, is Bell v. Clayton County Board of Education.
Conditioning in unsafe conditions
Imani Bell was a 16-year-old basketball player at Elite Scholars Academy outside Atlanta’s southern suburb of Jonesboro. On Aug. 13, 2019, with the heat index over 100 degrees and temperatures hovering between 92 and 97 degrees, Bell and the other members of the team were taking part in mandatory outdoor conditioning drills. As part of the that day's workout, the players were forced to run up and down the stairs at a football stadium. During the drill, Bell suffered heat stroke and never recovered.
It was determined that her cause of death was hyperthermia and rhabdomyolysis resulting from physical exertion in high ambient temperature. Hyperthermia is a condition in which the body is dangerously overheated, and rhabdomyolysis is a syndrome in which muscle fibers die, releasing proteins and enzymes into the blood. Rhabdomyolysis, often caused by extreme physical exertion, can be fatal or result in permanent disability.
As a result of her death, Imani Bell’s estate filed a wrongful death claim against the Clayton County Board of Education, which oversees Elite Scholars Academy. To recover for a wrongful death claim, the estate was compelled to show that the death was caused by the coach’s negligence. Therefore, the Bells had to show: 1) that the basketball coaches and school had a duty to conduct conditioning drills in a safe manner; 2) that the coaches breached that duty by conducting this particular drill in dangerous conditions; 3) that the breach of duty to Imani Bell was the cause of her injuries; and 4) that Bell suffered an injury or damages.
Based on the facts, it seems clear that the Bells had a valid case against the Clayton County Board of Education. The coaches and the school clearly had a duty to Imani and all the players on the team to conduct the practices in a safe environment. The coaches breached that duty by conducting the conditioning drills outside when the heat index was over 100 degrees, and temperatures hovered between 92 and 97 degrees. Also, by conducting the drills in the extreme heat, the coaches caused Bell to suffer heat stroke, which resulted in her death (injury). Presented with an unwinnable case, the school board agreed to settle with the Bell family for $10 million.
In addition to the negligent wrongful death claim, a Clayton County grand jury indicted Imani Bell’s coach, Larosa Maria Walker-Asekere, and the coach’s assistant, Dwight Broom Palmer, on charges of second-degree murder, finding that the coaches, “irrespective of malice, did cause the death of lmani Bell.” The two coaches were also indicted on charges of second-degree cruelty to children, involuntary manslaughter and reckless conduct, court records show. It should be noted that the coaches being indicted and charged does not mean they are guilty of the crimes. In fact, both coaches have pleaded not guilty and are currently out of jail awaiting trial after posting $75,000 bail.
Danger not limited to heat
While Bell v. Clayton County Board of Education was settled before the case ever got to trial, its $10 million cost should shock sport and recreation managers, as well as leave them with several takeaways.
First, athletic directors and school administrators need to establish clear guidelines for how coaches schedule preseason and in-season conditioning drills. As the NCCSIR report suggests, despite heavy media attention about potentially fatal risks, coaches are still overworking athletes in the heat, and athletes are still dying of heat-related episodes. Therefore, it is essential that schools establish guidelines on when practices can be held, and when athletes should get rest breaks for water and shade.
That said, it is not enough to merely have guidelines. As the Bells noted, the Elite Scholars Academy had safety guidelines in place, including the school system’s heat index. The coaches and administrators, however, failed to follow the established safety guidelines, resulting in the death of Imani Bell and a $10 million settlement.
Second, while coaches should already know the dangers associated with running practices in extreme temperatures, it seems that some coaches still have not gotten the message and are willing to push athletes to their limits in the interest of conditioning, winning or even punishment. This case should send a clear message to coaches that they have a legal duty to ensure they do not expose their athletes to greater risks than those inherent in the activity. If they do, the coaches and schools will be held negligent for any injuries resulting from their actions.
Third, if coaches are going to push their athletes to unhealthy extremes and recklessly endanger the athletes under their care by exposing them to dangerous conditions, tort liability is the least of their concerns. While Georgia is the first jurisdiction to criminally charge coaches for heat-related deaths, the case could lead to future criminal charges against coaches.
Finally, as illustrated by two situations that made headlines earlier this year, it must be noted that late-summer heat is not the only danger facing athletes. In January, five basketball players from Concordia University, a Division III school in Chicago, were hospitalized after their coach subjected the players to a grueling weekend practice, including circuit training, allegedly as punishment for the players breaking the team’s curfew earlier in the week. Just like lmani Bell, the players were suffering from conditions similar to lactic acidosis and rhabdomyolysis, which resulted in their hospitalization. The university temporarily removed the head coach, Steve Kollar.
Days later, John Harrell, the head football coach at Rockwall-Heath (Texas) High School, was suspended while under investigation after a particularly intense workout hospitalized multiple players. The athletes were reportedly instructed to do sets of 16 pushups with a 20- to 30-second rest in between. The mother of one of the players hospitalized said her son was not given water breaks and was diagnosed with rhabdomyolysis.
Whether in a gym in January or on a sweltering field in August, coaches and athletic administrators need to understand the duty they have to protect their athletes.
