Of importance, before resuming play, the injured playerapparently reported symptoms consistent with a head injuryto other players (that he suffered a collision to his head, hadblacked out, and had a headache) but never reported thesesymptoms to the athletic trainer, team physician, or coaches

In Zemke v Arreola,47 16-year-old Nicholas Zemke sustained asevere and debilitating head injury while playing varsity foot-ball for his high school. During a game he suffered a dislo-cated finger, which was treated by the athletic trainer andteam physician. The coach asked the team physician whetherthe player was “done for the day” and was advised that theycould tape it up and that he would be fine and ready to go.Thereafter the coach asked the player if he was ready to go;the player responded that his finger was fine, but that “I’mnot ready to go in now.” The coach responded, “Okay, whenyou are ready to go in, come back and let me know.” He soonresumed play and collapsed during a time-out, having suf-fered a right subdural hematoma

She alleged that the coaches told her she was theteam’s tallest player and needed to play in that night’s game.Plaintiff claimed they observed her shaking and having diffi-culty participating during warm-ups but still played her in thegame. The plaintiff’s mother took her to the hospital after thesecond game. Plaintiff alleged that the delay in receiving med-ical treatment caused her to suffer an exacerbation of her neu-rological condition.

Unlike professional sports and to a lesser degree colle-giate competition, where team physicians are uniformly onthe sidelines, one could question why coaches should even beinvolved in such a “medical” decision.

. To be familiar with features of concussion2. To evaluate player who appeared to have suffered headinjury for symptoms of concussion3. To repeat evaluation at intervals before player would bepermitted to reenter game4. To determine, based upon evaluation, seriousness of injuryand whether it was appropriate to let the player reenterthe game or to remove the player from all contact pendingmedical examination

n return-to-play cases, student-athletes usually allege thecoach or trainer negligently allowed the athlete to return toa game after suffering an injury.

Areas of Potential LiabilitiesCourts have recognized a number of areas of potential liabilityin the context of organized athletic events at the high schoollevel. The following is a nonexhaustive list:Preparticipation physicals and screening examinations•Providing or refusing initial medical clearance to play in any•particular athletic activityAdequate facilities and the availability of adequate medi-•cal equipment for use by team physicians and/or athletictrainersProviding adequate training in the use of particular safety•equipment and gear by the athletePlanning for athletic injuries and emergency situations that•may arise in the context of any individual athletic event andhaving those involved (including but not limited to physi-cians, team athletic trainers, and coaches) knowledgeablewith the applicable planDiagnosis and treatment of injuries occurring during the ath-•letic activityReturn-to-play medical decisions following assessment and•treatment of injuriesInformed consent in the context of clearance to play•The relationship between a team physician and athletic•trainer (whether certified or not) and appropriate supervisionRecommendations for and follow-up medical care and•assessmentsInappropriate disclosure of confidential medical informa-•tion, including violation of federal statutes such as HealthInsurance Portability and Accountability Act of 1996 (HIPAA)and Family Educational Rights and Privacy Act (FERPA)Inadequate certification/training/supervision of coaches,•physicians, athletic trainers, and othersPotential contributory negligence by the athlete•Maintenance of, knowledge of, and prescription of pharma-•ceutical drugs and other supplements

No national standard of care applies to healthcare pro-viders covering athletic events; hence, healthcare providersshould be aware of the standard of care applicable to themin their particular state as defined by the courts in that stateand under applicable regulations and statutes.

He developed pain in his knees, wasdiagnosed with patellar tendinitis, and contended that both thebasketball coach and athletic trainer were made aware of hiscomplaints but that the coach insisted he continue to play

and offer some “real life” examples of how courtsin various jurisdictions around the country have applied theseprinciples with a goal of bringing about awareness and furtherdiscussion